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Hinton v. Alabama

Supreme Court of the United States · 2014 · Criminal Procedure

Criminal ProcedureIneffective Assistance of CounselSixth AmendmentExpert Witness FundingStricklanddeficient performanceprejudiceexpert witness

Facts

The prosecution's case depended on expert testimony that six bullets from three robberies, including the two charged murders, had been fired from a revolver found at Hinton's house. Hinton's lawyer sought funds for a defense firearms and toolmark expert, but mistakenly believed Alabama law capped expert funding at $1,000 and therefore hired Andrew Payne, whom counsel himself regarded as inadequate. The trial judge had invited counsel to request more funds if necessary, and Alabama law actually allowed reimbursement for any expenses reasonably incurred with advance approval. At trial, the State strongly discredited Payne, while Hinton later produced three postconviction experts who testified they could not conclude that any of the six bullets had been fired from the revolver.

Issue

Whether Hinton's trial counsel rendered ineffective assistance under Strickland by failing to seek additional state funds for a better expert because counsel mistakenly believed Alabama law capped available expert funding at $1,000. If so, whether the Alabama courts applied the correct prejudice inquiry.

Rule

Under Strickland, counsel performs deficiently when representation falls below an objective standard of reasonableness, and prejudice exists when there is a reasonable probability that, but for counsel's errors, the result would have been different. A lawyer's ignorance of a point of law fundamental to the case, combined with failure to perform basic research on that point, is unreasonable performance; when a defense requires expert assistance, counsel must reasonably investigate the funding and resources available to obtain a competent expert.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a murder trial in Columbus, Ohio, the prosecution's case depends almost entirely on DNA mixture testimony linking Devin Cole to a jacket found near the scene. Devin's appointed lawyer tells the court he needs a defense DNA expert, but after receiving $1,200 he stops looking because he mistakenly believes state law sets a hard cap at that amount, even though the statute actually allows reimbursement of any reasonable defense expense with prior approval.

Under the governing ineffective-assistance rule, was counsel's performance most likely deficient?

Explanation. Deficient performance exists when counsel's representation falls below an objective standard of reasonableness. When the defense requires expert assistance, counsel must reasonably investigate what resources the law makes available. A lawyer's ignorance of a point of law fundamental to the case, combined with failure to do basic research, is unreasonable. Here, counsel stopped searching solely because of a mistaken legal belief about funding, not because of an informed strategic decision.