Category: Supreme Court Case Briefs

Pillars of the Supreme Court

Batson v. Kentucky, 476 U.S. 79 (1986)

FACTS: The State of Kentucky (Respondent) indicted Baston, a Black man (Petitioner) on charges of second-degree burglary and receipt of stolen goods. At trial, the prosecutor used his peremptory challenges to strike all Black persons on the venire, which left a jury composed only of White persons.

PROCEDURAL HISTORY: Defense counsel moved to discharge the jury before it was sworn on the ground that the prosecutor’s removal of the Black veniremen violated Petitioner’s constitutional rights. The trial judge denied the Petitioner’s motion. Thereafter, the jury convicted Petitioner on both counts. The Petitioner appealed to the Kentucky Supreme Court and raised the peremptory challenge argument. The Kentucky Supreme Court affirmed. The Petitioner appealed to the SCOTUS.

JUDGMENT: Reversed.

ISSUE: Whether a State’s exercise of peremptory challenges to exclude members of a Black defendant’s race, from a petit jury, violates the Sixth Amendment right to an impartial jury, and the Fourteenth Amendment right to equal protection of the laws.

HOLDING OF THE COURT: When a trial court decides that the facts establish purposeful discrimination and the prosecutor does not come forward with a neutral explanation for excluding a particular race from the jury, the Petitioner’s conviction must be reversed.

RATIONALE:. Due to the heterogeneous population of the U.S., SCOTUS requires trial courts to be sensitive to the racially discriminatory use of peremptory challenges and enforces the mandate of equal protection. Indeed, the exclusion of Black citizens from service as jurors is a primary example of the evil the Fourteenth Amendment was designed to cure. If courts ensure that no citizen is disqualified from jury service because of their race, public respect for the criminal justice system and the rule of law will be strengthened.

Medical care

Lassiter v. Department of Social Svcs., 452 U.S. 18 (1981)

FACTS: The Durham County Department of Social Services (Department) alleged, Abby Gail Lassiter did not provide her son William with proper medical care. Based on this fact, the Department took custody of William. The Department further claims Lassiter did not make future plans for William, ceased all contact with him, and left him in foster care.

PROCEDURAL HISTORY: The trial court served Lassiter (Petitioner) with the petition and with notice of hearing. At the hearing, the trial court terminated Petitioner’s parental rights. Petitioner argued on appeal that she was indigent. She further argued that the trial court violated her Fourteenth Amendment right to counsel when the trial court refused to provide counsel for her. The Appeals Court rejected Petitioner’s appeal and the Supreme Court of North Carolina affirmed the decision.

JUDGMENT: Affirmed.

ISSUE: Whether Petitioner the Due Process Clause requires the appointment of counsel when a State seeks to terminate an indigent’s parental status.

HOLDING OF THE COURT: The trial court did not err when it failed to appoint counsel for the Petitioner.

RATIONALE: SCOTUS articulated that the right to appointed counsel exists only where a litigant may lose her physical liberty if she loses the litigation. In the present case, the Petitioner expressly declined to appear at a child custody hearing. She also failed to speak to her retained lawyer after she was notified of the termination hearing. While Petitioner failed to make an effort to contest the termination proceeding, the litigation did not result in the loss of her physical liberty.

SYNTHESIS: It was not a struggle for SCOTUS to decide that the Eldridge factors—the protection of parental rights in judicial proceedings—did not overcome the presumption against the right to appointed counsel. Due process does not require the appointment of counsel in every parental termination proceeding. While Gideon v. Wainwright recognized that the Sixth Amendment right to counsel exists to protect the fundamental right to a fair trial, SCOTUS resurrected the decision of Betts v. Brady. In that case, SCOTUS decided that a defendant did not have a constitutional right to counsel. SCOTUS further relied on Betts and refused to extend the right to appointed counsel to include proceedings that did not result in a defendant’s loss of personal liberty. In SCOTUS’ view, as a litigant’s interest in personal liberty diminishes, so does their right to appointed counsel.

SEPARATE OPINION: (Blackmun, J.; Brennan, J.; Marshall,J., dissenting). The Dissenters argued that the unique importance of a parent’s interest in the care and custody of their child cannot constitutionally be extinguished through formal judicial proceedings without the benefit of counsel. To do so would revive the ad hoc approach that SCOTUS discredited in Gideon v. Wainwright. For instance, SCOTUS rejected the Betts reasoning that counsel for indigent criminal defendants was ‘not a fundamental right, essential to a fair trial.’ Although the Dissenters used the same approach to evaluate the “three distinct Eldridge factors” as the majority, it came to a different conclusion. In their view, the countervailing governmental interest was insubstantial. Thus, the majority should have decided whether Petitioner was given a meaningful opportunity to be heard when the State moved to terminate her parental rights.

Strickland v. Washington, 466 U.S. 688 (1984)

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.

JUDGMENT: Reversed.

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.

Evidentiary hearing

Goldberg v. Kelly, 397 U.S. 254 (1970)

FACTS: Residents of New York City receiving financial aid under the federally assisted program of Aid to Families with Dependent Children (AFDC) or under New York State’s general Home Relief program alleged that the New York State and New York City officials administering these programs terminated, or were about to terminate, such aid without prior notice and hearing, thereby denying them due process of law.

PROCEDURAL HISTORY: An action was brought in the District Court for the Southern District of New York. The District Court held that only a pre-termination evidentiary hearing would satisfy the constitutional command. It rejected New York officials’ argument that the combination of the post-termination ‘fair hearing‘ with the informal pre-termination review disposed of all due process claims.

JUDGMENT: Affirmed.

ISSUE: Whether the Due Process Clause requires that the recipient be afforded an evidentiary hearing before the termination of benefits.

HOLDING OF THE COURT: Due process requires an adequate hearing before termination of welfare benefits (later constitutionally fair proceeding does not alter the result).

RATIONALE: When welfare is discontinued, only a pre-termination evidentiary hearing provides the recipient with procedural due process. The pre-termination hearing need not take the form of a judicial or quasi-judicial trial. While the Court reasoned that counsel need not be provided at the pre-termination hearing, it did state that a recipient must be allowed to retain an attorney if [s]he so desires. The Court also noted that a welfare official’s prior involvement in some aspects of a case will not necessarily bar them from acting as a decision maker, however, they should not participate in the determination under review.

DISSENT: (Black, J.) When federal judges use judicial power for legislative purposes, they wander out of their field of vested powers and transgress into the area constitutionally assigned to the Congress and the people. Justice Black stated no provision in our Constitution paralyzes the governments’ efforts to protect itself against making payments to people who are not entitled to them. It strains credulity to say that the government’s promise of charity to an individual is property belonging to that individual when the government denies that the individual is honestly entitled to receive such a payment.

Justice Black felt the majority reached its result by a process of weighing ‘the recipient’s interest in avoiding’ the termination of welfare benefits against ‘the governmental interest in summary adjudication.’ According to Justice Black, today’s balancing act requires a ‘pre-termination evidentiary hearing,’ yet there is nothing that indicates what tomorrow’s balance will be. The end result of the Court’s decision may be that the government, once it decides to give welfare benefits, cannot reverse that decision until the recipient has had the benefits of full administrative and judicial review, including, the opportunity to present his case to this Court. For Justice Black, this case is a new experiment carrying out a welfare program that should not be frozen into the U.S.’s constitutional structure. It should be left, as are other legislative determinations, to the Congress and the legislatures that the people elect to make our laws.

Supreme Court of the United States

Gideon v. Wainwright, 372 U.S. 335 (1963)

FACTS: Clarence E. Gideon was charged in a Florida state court with having broken and entered a poolroom, a felony under Florida law. Gideon appeared in court without funds and without a lawyer, and asked the court to appoint counsel for him. However, the Court told Gideon that counsel could only be appointed to represent a defendant charged with a capital offense.

PROCEDURAL HISTORY: At jury trial, Gideon (Petitioner) conducted his own defense (i.e., self-represented litigation). However, the jury returned a verdict of guilty, and sentenced Gideon to serve five years in the state prison. Gideon filed a habeas corpus petition in the Florida Supreme Court. In the petition, Gideon argued the trial court’s refusal to appoint counsel denied him rights ‘guaranteed by the Constitution and the Bill of Rights by the United States Government.’ The State Supreme Court denied all relief.

JUDGMENT: Reversed.

ISSUE: Whether the Sixth Amendment’s right to counsel in criminal cases applies to felony defendants in state courts.

HOLDING OF THE COURT: The Court concluded that Betts v. Brady should be overruled. The Court further held that certain fundamental rights, safeguarded by the first eight amendments against federal action, are safeguarded against state action by the due process of law clause of the Fourteenth Amendment. One of those is the fundamental right of the accused to be assisted by counsel in a criminal prosecution.

RATIONALE: If the holding in Betts were left standing, it would require the Court to reject Gideon’s claim that the Constitution guarantees him the assistance of counsel. The Court stated any person hauled into court, who is too poor to hire a lawyer, cannot be assured a fair trial unless counsel is provided for him. It further reasoned that State and national constitutions and laws have laid great emphasis on procedural and substantive safeguards designed to assure fair trials before impartial tribunals in which every defendant stands equal before the law. At this point, the Court looked to the Sixth Amendment, which provides ‘In all criminal prosecutions, the accused shall enjoy the right…to have the assistance of counsel for his defense.’ The Court also looked to the Bill of Rights. There, the Court found that it contains fundamental safeguards of liberty that immune citizens from federal abridgment. In the Court’s view, citizens are equally protected against state invasion by the Due Process Clause of the Fourteenth Amendment.

SEPARATE OPINION: (Harlan, J) In Justice Harlan’s opinion, the declaration that the right to appointed counsel in state prosecutions, as established in Powell v. Alabama, was not limited to capital cases an extension of the Court’s precedent. While Justice Harlan did not embrace the concept that the Fourteenth Amendment ‘incorporates’ the Sixth Amendment, he did assert that a valid right or immunity against the Federal Government is valid against the States. In all, Justice Harlan believed the Court did not depart from the principles laid down in Palko v. Connecticut.

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