Schriro v. Landrigan
127 S. Ct. 1933 (2007)
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Rule of Law:
A federal court is not required to grant an evidentiary hearing on a habeas petitioner's ineffective assistance of counsel claim if the state court record establishes that the petitioner instructed counsel not to present mitigating evidence, thereby precluding a showing of prejudice under Strickland v. Washington.
Facts:
- In 1982, Jeffrey Landrigan was convicted of second-degree murder in Oklahoma.
- In 1986, while incarcerated, Landrigan stabbed another inmate and was convicted of assault with a deadly weapon.
- In 1989, Landrigan escaped from prison and murdered Chester Dean Dyer in Arizona.
- During the sentencing phase of his Arizona murder trial, Landrigan's counsel attempted to present mitigating testimony from Landrigan's ex-wife and birth mother.
- At his client's request, counsel informed the court that the witnesses would not testify.
- The trial judge questioned Landrigan directly, and he confirmed that he had instructed his lawyer not to present mitigating circumstances and stated, 'Not as far as I'm concerned' when asked if there were any.
- When his counsel attempted to make a proffer of the mitigating evidence, Landrigan repeatedly interrupted to correct the record, downplaying sympathetic facts and emphasizing his own culpability in prior violent acts.
- At the conclusion of the hearing, Landrigan told the judge, 'I think if you want to give me the death penalty, just bring it right on. I’m ready for it.'
Procedural Posture:
- An Arizona jury found Jeffrey Landrigan guilty of felony murder, and the trial judge sentenced him to death.
- On direct appeal, the Arizona Supreme Court affirmed the conviction and sentence.
- Landrigan filed a petition for postconviction relief in Arizona state court, which was dismissed by the trial court without an evidentiary hearing.
- The Arizona Supreme Court denied his petition for review of the postconviction ruling.
- Landrigan filed a petition for a writ of habeas corpus in the U.S. District Court for the District of Arizona.
- The District Court denied the petition and declined to hold an evidentiary hearing.
- Landrigan appealed to the U.S. Court of Appeals for the Ninth Circuit. A three-judge panel initially affirmed the District Court's denial.
- The Ninth Circuit then granted rehearing en banc and, in a divided opinion, reversed the District Court, holding that it abused its discretion by not holding an evidentiary hearing.
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Issue:
Does a federal district court abuse its discretion by denying an evidentiary hearing on an ineffective assistance of counsel claim where the state court made a reasonable factual determination that the defendant had instructed his counsel not to present any mitigating evidence?
Opinions:
Majority - Justice Thomas
No. A federal district court does not abuse its discretion by denying an evidentiary hearing in such circumstances. Under the deferential standards of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), a federal court must presume state court factual findings are correct. The Arizona court’s determination that Landrigan instructed his attorney not to present any mitigating evidence was a reasonable determination of the facts based on the trial colloquy and Landrigan's own disruptive and uncooperative behavior. Because Landrigan would have prevented the presentation of any mitigating evidence his counsel might have uncovered, he cannot establish the prejudice required for an ineffective assistance of counsel claim under Strickland. Therefore, an evidentiary hearing to develop facts about uninvestigated evidence would be futile.
Dissenting - Justice Stevens
Yes. The district court abused its discretion, as its conclusion that Landrigan would have refused to present any and all mitigation is 'pure guesswork' without an evidentiary hearing. A waiver of the constitutional right to present mitigating evidence must be knowing and intelligent, which was impossible here because counsel's constitutionally deficient investigation failed to uncover significant evidence, such as Landrigan's organic brain disorder. Landrigan could not knowingly waive the presentation of evidence he did not know existed. The state court's finding that he waived presentation of all mitigating evidence was an unreasonable determination of the facts, as the record suggests he only intended to prevent testimony from his ex-wife and birth mother. An evidentiary hearing is necessary to determine the prejudicial impact of his counsel's inadequate representation.
Analysis:
This decision significantly reinforces the high procedural hurdles established by AEDPA for federal habeas petitioners. It clarifies that a defendant's explicit, on-the-record obstruction of counsel's efforts to present a defense can foreclose a subsequent ineffective assistance of counsel claim, particularly regarding prejudice. The ruling curtails the availability of federal evidentiary hearings by holding that they are not required when the state record reasonably supports a finding that the petitioner's own actions would have rendered any further investigation by counsel futile. This strengthens the finality of state court factual determinations in federal habeas review.
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