Terrance Anderson v. State of Missouri
196 S.W.3d 28 (2006)
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Rule of Law:
A defense counsel's failure to move to strike a juror who is predisposed to impose the death penalty and who would require the defense to prove that a death sentence is not warranted constitutes ineffective assistance of counsel, resulting in a structural error that requires vacating the death sentence.
Facts:
- Terrance Anderson was in a relationship with Abbey Rainwater, the daughter of Debbie and Stephen Rainwater.
- Anderson and Abbey Rainwater had a child together.
- Anderson became paranoid that the Rainwaters were trying to take his child from him, which became a source of conflict.
- Anderson killed both Debbie and Stephen Rainwater.
Procedural Posture:
- A jury in a Missouri trial court convicted Terrance Anderson of two counts of first-degree murder.
- The jury recommended a death sentence for the murder of Debbie Rainwater and life without parole for the murder of Stephen Rainwater.
- Anderson's convictions and sentences were affirmed on direct appeal by the Missouri Supreme Court.
- Anderson filed a motion for post-conviction relief in the motion court (trial court) alleging ineffective assistance of counsel.
- After an evidentiary hearing, the motion court denied Anderson's motion for relief.
- Anderson (appellant) appealed the motion court's denial to the Missouri Supreme Court.
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Issue:
Does a defense counsel's failure to move to strike a juror who expressed a clear bias in favor of the death penalty and improperly shifted the burden of proof to the defense constitute ineffective assistance of counsel, requiring the reversal of a death sentence?
Opinions:
Majority - Per Curiam
Yes. A defense counsel's failure to move to strike a juror who improperly shifts the burden of proof in the penalty phase constitutes ineffective assistance of counsel, which is a structural error requiring the death sentence to be vacated. Applying the two-prong test from Strickland v. Washington, the court found counsel's performance was deficient because no reasonably competent attorney would permit a juror to serve who stated he would begin with the death penalty as the appropriate punishment and require the defense to convince him otherwise. Counsel admitted the failure to strike Juror Dormeyer was a note-taking error, not a reasonable trial strategy. The court found this deficient performance was prejudicial because the seating of a biased juror is a structural error that taints the fairness of the proceeding, particularly in a capital case. Such an error is not cured by the defense presenting a mitigation case and requires the sentence to be vacated without a harmless-error analysis. The court affirmed the guilt-phase conviction, however, finding that other alleged errors by counsel did not result in the prejudice required under Strickland.
Analysis:
This decision reinforces the critical importance of voir dire in capital cases and the stringent constitutional requirement for juror impartiality. It establishes that seating a juror who reverses the burden of proof during sentencing is not merely a trial error but a structural error, which is automatically prejudicial and requires reversal. The case serves as a stark warning to defense counsel that even unintentional oversights during jury selection can constitute ineffective assistance under the Sixth Amendment. Furthermore, by reversing only the penalty phase while upholding the conviction, the court demonstrates the severability of errors that affect different stages of a trial.
