Strickland v. Washington

Rule of Law:

To establish a claim of ineffective assistance of counsel under the Sixth Amendment, a criminal defendant must show both that counsel's performance was deficient (fell below an objective standard of reasonableness) and that the deficient performance prejudiced the defense (there is a reasonable probability that, but for counsel's errors, the result of the proceeding would have been different).

Facts:

• During a 10-day period in September 1976, David Washington committed three brutal stabbing murders along with torture, kidnappings, and other violent felonies.
• After his accomplices were caught, Washington surrendered and confessed to the third murder.
• Against the specific advice of his appointed counsel, Washington later confessed to the first two murders as well.
• Acting against his counsel's advice again, Washington waived his right to a jury trial and pleaded guilty to all charges, including three counts of capital murder.
• Washington also rejected his counsel's advice to have an advisory jury for his sentencing hearing, choosing to be sentenced by the judge alone.
• In preparing for sentencing, counsel's investigation into mitigating evidence was limited; he spoke to Washington's wife and mother by phone once but did not follow up, did not seek other character witnesses, and did not request a psychiatric evaluation.
• Counsel made a strategic decision to not present mitigating character or psychological evidence to prevent the State from cross-examining Washington and introducing its own damaging psychiatric evidence or Washington's criminal history.
• Counsel's sentencing argument relied on Washington's remorse, acceptance of responsibility expressed during the plea colloquy, and the statutory mitigating circumstances of emotional distress and lack of a significant criminal history.

Procedural Posture:

• David Washington pleaded guilty and was sentenced to death in a Florida state trial court.
• The Florida Supreme Court affirmed the convictions and sentences on direct appeal.
• Washington filed a petition for collateral relief in the state trial court, alleging ineffective assistance of counsel at sentencing, which the court denied without an evidentiary hearing.
• The Florida Supreme Court affirmed the denial of collateral relief.
• Washington filed a petition for a writ of habeas corpus in the U.S. District Court for the Southern District of Florida.
• The District Court held an evidentiary hearing but ultimately denied the petition, finding no prejudice.
• The U.S. Court of Appeals for the Eleventh Circuit, hearing the case en banc, reversed the District Court, establishing its own new standard for ineffective assistance claims and remanding for new factfinding under that standard.
• The State of Florida (represented by Strickland, the prison superintendent) petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.