Rompilla v. Beard
545 U.S. 374 (2005)
Rule of Law:
Under the Sixth Amendment, a defense counsel in a capital case has a constitutional duty to make reasonable efforts to obtain and review materials that counsel knows the prosecution will use as aggravating evidence, even if the defendant and his family members have suggested no mitigating evidence is available.
Facts:
- On January 14, 1988, James Scanlon was found stabbed to death and set on fire in the bar he ran in Allentown, Pennsylvania.
- Ronald Rompilla, who was at the bar on the night of the murder, was identified as a suspect.
- Physical evidence linked Rompilla to the crime, including a bloody footprint matching his sneakers and his fingerprint on one of the knives used in the attack.
- After leaving the bar, Rompilla checked into a motel under a false name with a large amount of cash, and the victim's wallet was discovered outside his room.
- Rompilla had a prior 1974 conviction for rape and assault.
- The Commonwealth of Pennsylvania notified Rompilla's defense counsel of its intent to seek the death penalty and to use the prior conviction as an aggravating factor.
- The court file for this prior conviction was a public document, readily available at the courthouse where Rompilla was being tried.
Procedural Posture:
- Ronald Rompilla was convicted of murder and sentenced to death in a Pennsylvania state trial court.
- On direct appeal, the Supreme Court of Pennsylvania affirmed the conviction and sentence.
- Rompilla filed a petition for post-conviction relief in state court, alleging ineffective assistance of counsel, which the trial court denied.
- The Supreme Court of Pennsylvania affirmed the denial of post-conviction relief.
- Rompilla then filed a petition for a writ of habeas corpus in the U.S. District Court for the Eastern District of Pennsylvania.
- The District Court granted habeas relief, finding that Rompilla's counsel had been ineffective during the penalty phase.
- The Commonwealth of Pennsylvania, the respondent, appealed to the U.S. Court of Appeals for the Third Circuit.
- A divided panel of the Third Circuit reversed the District Court's decision, holding that the state court's application of Strickland was not unreasonable.
- The U.S. Supreme Court granted certiorari to review the Third Circuit's decision.
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Issue:
Does a defense counsel's failure to examine the case file of a defendant's prior conviction, when counsel knows the prosecution will use that conviction as an aggravating factor at the capital sentencing phase, constitute ineffective assistance of counsel in violation of the Sixth Amendment?
Opinions:
Majority - Justice Souter
Yes. A defense counsel's failure to examine the readily available case file of a defendant's prior conviction, which counsel knows the prosecution will use for aggravation in a capital sentencing, constitutes deficient performance under Strickland v. Washington. The duty to conduct a reasonable investigation requires counsel to examine materials they know the prosecution will rely on, regardless of the defendant's or his family's statements that no mitigating evidence exists. It is unreasonable to forgo reviewing such a file, as it is a 'sure bet' to reveal the prosecution's strategy and may contain undiscovered mitigating evidence or context for the prior crime. Here, counsel's failure was prejudicial because the file contained a wealth of undiscovered mitigating evidence—including records of a traumatic childhood, fetal alcohol syndrome, organic brain damage, and low cognitive function—that creates a reasonable probability the jury would have returned a different sentence.
Dissenting - Justice Kennedy
No. The defense counsel's performance was not constitutionally deficient, and the majority imposes a new, rigid per se rule that contravenes the flexible standard of Strickland. Counsel conducted a conscientious investigation by interviewing Rompilla, speaking with his family, and consulting three mental health experts. Their decision not to review the entire prior conviction file was a reasonable allocation of limited resources, as they were already aware of the brutal nature of the prior crime and could strategically conclude that challenging its details would be fruitless. Furthermore, Rompilla failed to demonstrate prejudice, as the discovery of the mitigating evidence within an obscure prison transfer document in the file would have been based on pure serendipity, not a targeted review.
Concurring - Justice O'Connor
Yes. The counsel's performance was constitutionally deficient under the specific circumstances of this case, which does not create a new rigid rule but properly applies Strickland. The failure to review the file was unreasonable because: 1) the prior conviction was central to the prosecution's aggravation case; 2) it threatened to eviscerate the defense's primary mitigation strategy of residual doubt; and 3) the failure to review the file was the result of inattention, not a reasoned, informed tactical decision. This conduct fell below the standard of reasonable professional judgment required by the Sixth Amendment.
Analysis:
This decision significantly clarifies the 'deficient performance' prong of the Strickland test for ineffective assistance of counsel, especially concerning the duty to investigate in capital cases. It establishes that a reasonable investigation includes, at a minimum, reviewing materials counsel knows the prosecution will use as aggravating evidence. The ruling heightens the obligations of capital defense attorneys, moving beyond reliance on client interviews and toward a more proactive duty to examine the prosecution's known evidence. This creates a clear baseline for performance, making it harder for counsel to justify a failure to review readily available and critical documents that are central to the sentencing phase of a capital trial.
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