United States v. Cronic
466 U.S. 648 (1984)
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Rule of Law:
A claim of ineffective assistance of counsel under the Sixth Amendment generally requires the defendant to show specific, prejudicial errors made by counsel, unless the surrounding circumstances are so deficient that they constitute a complete denial of counsel or a total failure of the adversarial process.
Facts:
- Respondent Cronic and two associates engaged in a mail fraud scheme involving over $9.4 million in checks transferred between banks in Florida and Oklahoma during a four-month period in 1975.
- The U.S. Government conducted a four-and-a-half-year investigation into the complex financial scheme.
- Shortly before the trial was scheduled to begin, Cronic's retained counsel withdrew from the case.
- The trial court appointed a young lawyer, whose principal practice was in real estate, to represent Cronic.
- The court granted the newly appointed counsel only 25 days for pretrial preparation.
- Cronic's two codefendants entered into plea agreements and agreed to testify for the government against him.
- At trial, Cronic's counsel did not present a defense case but did cross-examine the government's witnesses.
Procedural Posture:
- Cronic was convicted in the U.S. District Court on 11 counts of mail fraud and sentenced to 25 years in prison.
- Cronic appealed his conviction to the U.S. Court of Appeals for the Tenth Circuit.
- The Court of Appeals (appellant: Cronic, appellee: United States) reversed the conviction, inferring a violation of the Sixth Amendment right to effective counsel from the circumstances of the representation without finding any specific errors made by counsel.
- The United States (petitioner) was granted a writ of certiorari by the Supreme Court of the United States to review the appellate court's decision.
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Issue:
Does a criminal defendant establish a Sixth Amendment violation for ineffective assistance of counsel by showing that external circumstances, such as limited preparation time and counsel's inexperience, hampered the lawyer's preparation, without demonstrating specific errors by counsel that prejudiced the defense?
Opinions:
Majority - Justice Stevens
No. A criminal defendant does not establish a Sixth Amendment violation for ineffective assistance of counsel merely by showing circumstances that hampered the lawyer's preparation; a claim of ineffective assistance generally requires a showing of specific errors by counsel that prejudiced the defense. The Sixth Amendment's guarantee of counsel is meant to ensure a fair adversarial process. While some circumstances are so egregious that they create a presumption of prejudice—such as the complete denial of counsel, a lawyer's total failure to subject the prosecution's case to meaningful adversarial testing, or a situation where no lawyer could render effective assistance (as in Powell v. Alabama)—this case does not meet that high standard. Factors like the time afforded for preparation, counsel's experience, or the complexity of the case are relevant to evaluating an attorney's actual performance, but they do not, by themselves, justify a presumption that the trial was constitutionally unfair. The defendant must typically point to specific errors in counsel's performance that undermined the reliability of the trial's outcome.
Analysis:
This case significantly clarifies the standard for ineffective assistance of counsel claims, distinguishing between claims based on specific attorney errors and those where prejudice is presumed. By setting a very high bar for presuming ineffectiveness, Cronic ensures that convictions are not easily overturned based on circumstantial factors alone. The decision reinforces the principle that the Sixth Amendment protects the fundamental fairness of the adversarial process itself, not the abstract quality of the attorney-client relationship. It establishes that, absent a complete breakdown of the adversarial system, a defendant must prove actual, prejudicial errors, a standard later detailed in the companion case, Strickland v. Washington.
