Wiggins v. Smith Case Brief

Why is the case important?

Defendant on trial for murder argued that his attorney failed by not examining his background and other mitigating evidence of his life.

Facts of the case

“Kevin Wiggins was convicted and sentenced to death for a 1988 murder. He appealed, claiming that his attorney’s decision not to tell jurors about Wiggins’ troubled childhood amounted to ineffective counsel because it resulted in a harsher sentence. Prosecutors countered that the attorney’s decision had been carefully considered, and that a different decision would not necessarily have resulted in a different outcome. Therefore, they said, it was not ineffective counsel. A Maryland district court sided with Wiggins

  • the Maryland Supreme Court reversed, siding with the state. On appeal to federal court, the 4th Circuit Court of Appeals affirmed, ruling for Maryland.”

    Question

    Whether an attorney’s failure to investigate a defendant’s background and present mitigating evidence of his unfortunate life history at his capital sentencing proceedings violated his Sixth Amendment right to counsel.

    Answer

    “Yes. Applying a test of reasonableness to the counsels’ decision, the Supreme Court first found that the investigation drew from three sources: a psychologist

  • a written PSI, including a one-page account of Wiggins’ personal history, and
  • records from the Baltimore City Department of Social Services (DSS). Counsel’s decision not to expand their investigation beyond the.
  • “”>

    Conclusion

    The U.S. Supreme Court held that counsel’s decision not to expand their investigation beyond the pre-sentence report and department of social services (DSS) records fell short of professional standards prevailing in the state. The mitigating evidence that counsel failed to discover and present was relevant to assessing the inmate’s moral culpability. Given the nature and the extent of the abuse the inmate suffered, there was a reasonable probability that a competent attorney would have introduced it at sentencing. Moreover, had the jury been confronted with the evidence, a reasonable probability existed that it would have returned a different sentence.

    • Case Brief: 2003
    • Petitioner: Wiggins
    • Respondent: Smith
    • Decided by: Rehnquist Court

    Citation: 539 US 510 (2003)
    Argued: Mar 24, 2003
    Decided: Jun 26, 2003