Wood v. Allen

PETITIONER: Holly Wood
RESPONDENT: Richard F. Allen, Commissioner, Alabama Department of Corrections, et al.
LOCATION:

DOCKET NO.: 08-9156
DECIDED BY: Roberts Court (2009-2010)
LOWER COURT: United States Court of Appeals for the Eleventh Circuit

CITATION: 558 US (2010)
GRANTED: May 18, 2009
ARGUED: Nov 04, 2009
DECIDED: Jan 20, 2010

ADVOCATES:
Corey L. Maze - Solicitor General of Alabama, for the respondents
Kerry A. Scanlon - for the petitioner

Facts of the case

In 1994, Holly Wood was convicted in an Alabama state court of capital murder during a first-degree burglary and sentenced to death. Both the Alabama Court of Criminal Appeals and the Alabama Supreme Court affirmed the conviction and sentence. Mr. Wood subsequently filed for post-conviction relief under Alabama Rule of Criminal Procedure 32, arguing that he was mentally retarded and thus not eligible for a death sentence and that his trial counsel was ineffective. The Rule 32 court disagreed and denied his petition. Mr. Wood then filed for federal habeas corpus relief in an Alabama federal district court. The district court granted relief, agreeing that Mr. Wood's counsel was ineffective at sentencing because they failed to present evidence of Mr. Wood's deficient intellectual deficiencies.

On appeal, the U.S. Court of Appeals for the Eleventh Circuit reversed. It held that Mr. Wood's counsel was not ineffective. The court reasoned that Mr. Wood's attorneys acted reasonably when they decided it was in Mr. Wood's best interest to leave out information that illustrated his mental deficiencies. Moreover, the court recognized that while Mr. Wood's counsel included an inexperienced attorney, he merely acted as an assistant to the two experienced attorneys chiefly responsible for the case.

Question

1) Is a state court's decision on post-conviction relief unreasonable when it concludes that during the sentencing phase of a capital case that an inexperienced attorney's decision not to present evidence of the defendant's intellectual deficiencies was strategic, while ignoring evidence that demonstrated otherwise?

2) Did the rule followed by the Eleventh Circuit in this case abdicate its judicial review function under the Antiterrorism and Effective Death Penalty Act by failing to determine whether the state court decision was unreasonable in light of the entire state court record?

Media for Wood v. Allen

Audio Transcription for Oral Argument - November 04, 2009 in Wood v. Allen

Audio Transcription for Opinion Announcement - January 20, 2010 in Wood v. Allen

John G. Roberts, Jr.:

Justice Sotomayor has the opinion of the Court in case 08-9156, Wood vs. Allen.

Sonia Sotomayor:

The entitle as an Effective Death Penalty Act of 1996 contains two provisions governing Federal Court review of state court factual findings.

Under 28 USC Section 2254 (d)(2), a Federal Court may not grant a state petitioner's application for a writ of Habeas Corpus unless the state court's adjudication of the prisoner's claim “resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State Court proceeding.”

Under Section 2254 (e)(1), “a determination of a factual issue made by a State Court in co-presumed to be correct” and the petitioner has the quote “burden of rebutting the presumption of correctness by clear and convincing evidence."

In this case petitioner Hollywood, an Alabama death row inmate, brought a Federal Habeas petition in which he challenged the key factual determination made by the state court that denied the application for post conviction relief.

The State Court had found that the failure of Wood's attorneys to pursue and present mitigating evidence of his borderline mental retardation was a strategic decision rather than a negligent omission.

The Federal District Court ruled in Wood's favor, but the Court of Appeals for the Eleventh Circuit reversed.

We granted certiorari to resolve a conflict among the circuits concerning the relationship between Section 2254(d)(2) and Section 2254(e)(1) and to consider whether the state court reasonably determined that Wood's counsel made a strategic decision not to pursue or present evidence of his mental deficiencies.

Because our view of the reasonableness of the State Court's factual determination does not turn on the interplay between Section 2254(d)(2) and 2254(e)(1), we do not reach that question.

Instead we assume as Wood would have us hold that the State Court's factual determination should be reviewed only under the arguably less stringent standard of Section 2254(d)(2).

We conclude that under that Section, the State Court's factual findings that Wood's counsel made a strategic decision not to pursue or present evidence of Wood's mental deficiencies was not unreasonable in light of the evidence presented in the State Court proceedings, while the term unreasonable is difficult to define.

A State Court's factual determination is not unreasonable merely because the Federal Habeas Court would have reached a different conclusion in the first instance.

In this case the evidence in the State Court demonstrated that all three of Wood's counsels read a psychological report indicating that Wood's intellectual functioning was borderline and decided that nothing in the report merited further investigation.

The evidence also demonstrated that counsel consciously decided not to introduce the report to the jury.

This evidence can fairly be read to support the State Court's factual determination that counsel's failure to pursue or present evidence of Wood's mental deficiencies was not mere oversight or neglect, but was instead the result of a deliberate strategy to focus on other defenses.

In reaching that conclusion, we express no view as to whether Wood's counsel performed efficiently by failing to make a reasonable investigation of Wood's mental deficiencies before deciding not to pursue or present such evidence.

This argument is not fairly included in the questions presented and we therefore do not address it.

Accordingly we affirm the judgment of the Court of Appeals for the Eleventh Circuit.

Justice Stevens has filed the dissenting opinion in which Justice Kennedy joined.