FACTS: Charles E. Strickland kidnapped, tortured, murdered, assaulted, extorted victims and committed theft. Strickland later confessed to a third of the criminal episodes.
PROCEDURAL HISTORY: The State of Florida indicted Strickland (Respondent) for kidnaping and murder, and appointed an experienced criminal lawyer to represent him. Counsel advised Respondent to invoke his right under Florida law to an advisory jury at his capital sentencing hearing. Respondent rejected the advice and waived the right. The case proceeded to bench trial. There, Counsel did not seek out character witnesses for Respondent, nor did he cross-examine the medical experts who testified about the manner of death of Respondent’s victims. The trial judge sentenced Respondent to the death penalty. The Florida Supreme Court upheld the convictions and sentences on direct appeal. Thereafter, the Respondent appealed the decision and argued ineffective assistance at the sentencing proceedings.
ISSUE: Whether the Constitution requires a conviction or death sentence to be set aside because counsel’s assistance at the trial or sentencing was ineffective.
HOLDING OF THE COURT: The Court held the District Court properly declined to issue a writ of habeas corpus, as Respondent suffered insufficient prejudice to warrant setting aside his death sentence.
RATIONALE: A court hearing on an ineffectiveness claim must consider the totality of the evidence before the judge or jury. In order for a defendant to succeed on an ineffective assistance claim, he must show that counsel’s performance was deficient. In other words, counsel made errors so serious that counsel had not functioned as “counsel” guaranteed the defendant by the Sixth Amendment. The defendant must also show that the deficient performance prejudiced the defense. This requires showing that counsel’s errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable. Respondent asserted counsel was ineffective because he failed to move for a continuance, did not request a psychiatric report, nor investigated and presented character witnesses. Respondent further argued Counsel did not seek a presentence investigation report, did not investigate the medical examiner’s reports, nor cross-examine the medical experts. The Court found the omitted evidence to be irrelevant, and stated there was no reasonable probability that it would have changed the conclusion of the sentence imposed.
SYNTHESIS: In Gideon v. Wainwright, the Court recognized that the Sixth Amendment right to counsel exists to protect the fundamental right to a fair trial. The Constitution guarantees a fair trial through the Due Process Clauses, which includes the right to have the Assistance of Counsel for a defense. While the Court acknowledged that the effective assistance guarantee of the Sixth Amendment is to ensure that criminal defendants receive a fair trial, it did not find the deficiencies in Counsel’s performance in the present case prejudicial enough to the defense to constitute ineffective assistance under the Constitution.
SEPARATE OPINION: (Brennan, J.) Justice Brennan wanted to vacate the Respondent’s death sentence because he believes the death penalty is cruel and unusual punishment forbidden by the Eighth and Fourteenth Amendments.
Justice Marshall (dissenting) argued that “every defendant is entitled to a trial in which his interests are vigorously and conscientiously advocated by an able lawyer.” A proceeding in which the defendant does not receive meaningful assistance, in Justice Marshall’s view, does not constitute due process. Justice Marshall further stated if counsel had investigated evidence, he could have presented that evidence at trial. If additional evidence were presented, it could a resulted in the Respondent being given a life sentence instead of the death penalty. In all, Justice Marshall contends Counsel’s failure to investigate was more than sufficient to establish a violation of the Sixth Amendment and to entitle respondent to a new sentencing proceeding.