Terry Williams v. Taylor

Supreme Court of the United States · 2000 · Federal Courts

Federal CourtsHabeas CorpusIneffective Assistance of CounselAEDPA28 U.S.C. § 2254(d)(1)contrary tounreasonable applicationclearly established Federal law

Facts

Williams was sentenced to death after his lawyers presented only minimal mitigation evidence at sentencing, consisting mainly of brief favorable character testimony and a taped psychiatric excerpt. In later state habeas proceedings, substantial additional mitigation evidence emerged, including records of severe childhood abuse and neglect, evidence that Williams was borderline mentally retarded, and evidence from prison officials and records suggesting he functioned well in a structured environment and was not likely to be violent there. The state trial judge who heard the habeas evidence concluded counsel had been ineffective at sentencing and that there was a reasonable probability the result would have been different, but the Virginia Supreme Court rejected that conclusion. The Virginia Supreme Court treated Lockhart v. Fretwell as requiring more than outcome-based prejudice and minimized the omitted mitigation evidence.

Issue

Whether Williams was denied effective assistance of counsel at the sentencing phase under Strickland v. Washington, and whether the Virginia Supreme Court's rejection of that claim was contrary to, or an unreasonable application of, clearly established Federal law under 28 U.S.C. § 2254(d)(1).

Rule

Strickland supplies the clearly established federal law governing ineffective-assistance claims: a defendant must show deficient performance and prejudice, meaning a reasonable probability that, but for counsel's unprofessional errors, the result would have been different. Under § 2254(d)(1), habeas relief is available when the state court's decision is contrary to or involves an unreasonable application of that clearly established law; Lockhart does not displace Strickland's ordinary prejudice inquiry except in unusual circumstances where the claimed different outcome would have been a legal windfall rather than the loss of a right to which the defendant was entitled.

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

In a capital case in Georgia, Malik Turner filed a federal habeas petition alleging ineffective assistance at sentencing. The Georgia Supreme Court had rejected his claim after stating that counsel error is prejudicial only if the defendant proves by a preponderance of the evidence that the sentence would have been different. Turner argues the state court used the wrong constitutional standard.

Under the governing doctrine, how should the federal court characterize the state court's decision?

Explanation. Strickland is clearly established federal law for ineffective-assistance claims, and prejudice requires a reasonable probability of a different result, not proof by a preponderance. A state court decision is contrary to clearly established law when it applies a rule that contradicts the governing rule. That is the defect here.