Hinton v. Alabama
571 U.S. 263, 188 L. Ed. 2d 1, 2014 U.S. LEXIS 1012 (2014)
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Rule of Law:
An attorney's failure to seek additional funding to hire a qualified expert witness, when that failure is based on an unreasonable mistake of law about the availability of such funds rather than a strategic decision, constitutes deficient performance under the Sixth Amendment.
Facts:
- In 1985, two restaurant managers were killed and a third, Smotherman, was injured in three separate robberies involving a .38 caliber firearm.
- Police recovered six bullets from the crime scenes and a .38 caliber revolver from the home Anthony Ray Hinton shared with his mother.
- Smotherman identified Hinton as his assailant from a photographic array.
- State forensic examiners concluded that all six bullets were fired from the revolver found at Hinton's house, which became the only physical evidence linking Hinton to the murders.
- Hinton's defense attorney recognized the need for an expert to rebut the state's ballistics evidence.
- The attorney believed, incorrectly, that Alabama law capped funding for an expert at $1,000 for Hinton's two capital murder charges.
- Unable to find a qualified expert willing to work for that amount, the attorney hired Andrew Payne, an expert he knew was inadequate and whose expertise was in military ordnance, not firearms identification.
- In reality, an Alabama statute in effect at the time allowed for reimbursement of 'any expenses reasonably incurred' for an indigent defendant's defense.
Procedural Posture:
- Anthony Ray Hinton was convicted of two counts of capital murder in an Alabama state trial court and sentenced to death.
- Hinton filed a petition for postconviction relief in the state circuit court, alleging ineffective assistance of counsel; the court denied the petition.
- Hinton appealed to the Alabama Court of Criminal Appeals, which affirmed the circuit court's denial of his petition.
- The Supreme Court of Alabama reversed and remanded, instructing the lower court to determine whether Hinton's trial expert was qualified.
- On remand, the circuit court found the expert was qualified under the standard applicable at the time of the trial.
- The Alabama Court of Criminal Appeals affirmed this finding.
- The Supreme Court of Alabama denied Hinton's petition for review.
- Hinton petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does a defense attorney's failure to seek available funding for a competent forensics expert, due to a mistaken belief that the law capped such funding, constitute constitutionally deficient performance under Strickland v. Washington?
Opinions:
Majority - PER CURIAM
Yes. An attorney’s representation falls below an objective standard of reasonableness when it is based on ignorance of a fundamental point of law that is critical to the defense. The Sixth Amendment right to counsel requires a competent attorney, and competency includes a duty to make reasonable investigations into the law and facts. Here, the defense attorney's failure to seek additional funds for a qualified ballistics expert was not a strategic choice but was based on a mistaken belief that state law capped funding at $1,000. This ignorance of a clear state statute that provided for reimbursement of 'any expenses reasonably incurred' was an unreasonable error. This failure to perform basic research on a point of law fundamental to the case is a quintessential example of deficient performance under Strickland. Because the lower courts evaluated the prejudice prong of the Strickland test under an incorrect legal standard, the case is remanded for a proper determination of whether this deficient performance prejudiced the outcome of the trial.
Analysis:
This case clarifies the 'deficient performance' prong of the Strickland test for ineffective assistance of counsel. It establishes that an attorney's duty of reasonable investigation extends not just to facts, but also to the laws governing the resources available for a client's defense. The decision makes clear that a mistake of law regarding available funding is not a strategic choice that is 'virtually unchallengeable,' but can be a fundamental error constituting deficient performance. This precedent strengthens the Sixth Amendment protections for indigent defendants by holding counsel accountable for understanding and utilizing the tools the law provides for mounting an effective defense, particularly in cases hinging on expert testimony.
