United States v. Cronic Case Brief

Why is the case important?

Two defendants in a mail fraud case were appointed an attorney with limited experience and preparation time.

Facts of the case

“During a four-month period in 1975, Harrison P. Cronic, along with Carolyn Cummings and Wylie C. Merritt, participated in a mail fraud that involved transferring more than $9,400,000 in checks between a bank in Tampa, FL, and one in Norman, OK. The three were indicted on mail fraud charges. Shortly before trial, Cronic’s counsel withdrew and the court appointed a lawyer for him. The court appointed a lawyer who specialized in real estate law and only had 25 days to prepare for the trial, compared to the government’s almost five years. Cummings and Merritt agreed to testify for the government. The jury found Cronic guilty on and he was sentenced to 25 years in prison.The Court of Appeals concluded that Cronic’s Sixth Amendment right to effective assistance of counsel had been violated and reversed the conviction.”

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Conclusion

The United States Supreme Court held that the criteria used by the Tenth Circuit did not prove that counsel’s defense was ineffective. Counsel’s preparation time and his inexperience did not justify a presumption of ineffectiveness. Also, the gravity of the charge, the complexity of the case, and the accessibility of witnesses were not circumstances, in themselves, that made it unlikely that Cronic received effective assistance of counsel. The Court concluded that, on remand, Cronic could make out an ineffective assistance claim only by alleging specific errors made by trial counsel.

  • Case Brief: 1984
  • Petitioner: United States
  • Respondent: Harrison P. Cronic
  • Decided by: Burger Court

Citation: 466 US 648 (1984)
Argued: Jan 10, 1984
Decided: May 14, 1984