Strickland v. Washington Case Brief

Facts of the case

David Washington pleaded guilty to murder in a Florida state court. At sentencing, his attorney did not seek out character witnesses or request a psychiatric evaluation. Subsequently, the trial court sentenced Mr. Washington to death finding no mitigating circumstances to rule otherwise. After exhausting his state court remedies, Mr. Washington sought habeas corpus relief in a Florida federal district court. He argued that his Sixth Amendment right was violated because he had ineffective assistance of counsel at sentencing. The district court denied the petition. On appeal, the U.S. Court of Appeals for the Fifth Circuit reversed. The court held that the Sixth Amendment accorded criminal defendants a right to counsel rendering reasonably effective assistance given the totality of the circumstances.It then remanded the case to the district court to apply this standard and determine whether Mr. Washington’s counsel was sufficiently prejudicial to justify the reversal of his sentence.

Why is the case important?

After being sentenced to death, Petitioner filed for a writ of Habeas Corpus on the grounds that he was given ineffective assistance of counsel.

Question

Whether, after a defendant has pled guilty in a capital murder case, counsel has a duty to present mitigating evidence, in order to meet the Sixth Amendment standard for effectiveness.

ANSWER

The Supreme Court, in an opinion authored by Justice O’Connor, held that while counsel may have committed error, it was not so ineffective as to overturn a death sentence.

CONCLUSION

On appeal, the death sentence was affirmed. In support of its ruling, the Supreme Court held that in order to show that counsel’s assistance was so defective as to require reversal of a death sentence, defendant must have shown counsel’s performance was deficient, and that such deficient performance prejudiced the defense. In applying this standard, the Court further held that defense counsel’s performance could not be deemed unreasonable, and even if such were the case, defendant suffered insufficient prejudice to warrant setting aside his death sentence. In addition, in failing to make a showing that the justice of his sentence was rendered unreliable by a breakdown in the adversary process caused by deficiencies in counsel’s assistance, defendant also failed to show that his sentencing proceeding was fundamentally unfair.

  • Advocates: Carolyn M. Snurkowski on behalf of the Petitioners Richard E. Shapiro on behalf of the Respondent Calvin L. Fox for petitioners
  • Petitioner: Strickland
  • Respondent: Washington
  • DECIDED BY:Burger Court
  • Location: Eleventh Judicial Circuit of Florida – Dade County
Citation: 466 US 668 (1984)
Argued: Jan 10, 1984
Decided: May 14, 1984
Strickland v. Washington Case Brief