Williams v. Taylor
529 U.S. 362 (2000)
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Rule of Law:
Under the Antiterrorism and Effective Death Penalty Act (AEDPA), a federal court may grant a writ of habeas corpus if a state court decision was either "contrary to" clearly established federal law (by applying the wrong legal rule or deciding a case with materially indistinguishable facts differently) or involved an "unreasonable application of" that law (by applying the correct rule to the facts in an objectively unreasonable manner). A counsel's failure to conduct a thorough investigation into mitigating evidence for a capital sentencing hearing constitutes ineffective assistance if there is a reasonable probability the undiscovered evidence would have changed the outcome.
Facts:
- In November 1985, Harris Stone was found dead in his Danville, Virginia residence.
- Six months later, Terry Williams, who was incarcerated for an unrelated offense, wrote a letter to the police confessing to killing Stone.
- In a subsequent statement, Williams admitted he killed Stone with a mattock after Stone refused to lend him money.
- Williams also confessed to other violent crimes, including a brutal assault on an elderly woman that left her in a vegetative state.
- During Williams's childhood, his parents were imprisoned for criminal neglect of him and his siblings.
- Williams's father severely and repeatedly beat him, and Williams was placed in an abusive foster home for a period.
- Records, which were not discovered by trial counsel, indicated Williams was "borderline mentally retarded."
- Williams's trial counsel did not investigate his background and failed to uncover or present any of this mitigating evidence at his capital sentencing hearing.
Procedural Posture:
- Terry Williams was convicted of robbery and capital murder in a Virginia state trial court.
- Following the jury's recommendation, the trial judge imposed the death sentence.
- The Virginia Supreme Court affirmed the conviction and sentence on direct appeal.
- Williams filed a state habeas corpus petition, claiming ineffective assistance of counsel at sentencing.
- The state trial judge who heard the habeas petition found that counsel had been ineffective and recommended a new sentencing hearing.
- The Virginia Supreme Court reviewed the recommendation and reversed, holding that Williams had not established prejudice under Strickland.
- Williams filed a petition for a writ of habeas corpus in the U.S. District Court for the Eastern District of Virginia.
- The District Court granted the writ, finding the Virginia Supreme Court's decision was contrary to and an unreasonable application of federal law.
- On appeal by the warden, the U.S. Court of Appeals for the Fourth Circuit reversed the District Court's decision.
- The U.S. Supreme Court granted certiorari.
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Issue:
Was the Virginia Supreme Court's decision rejecting Terry Williams's ineffective assistance of counsel claim—based on his counsel's failure to investigate and present significant mitigating evidence at his capital sentencing—contrary to, or an unreasonable application of, clearly established federal law as set forth in Strickland v. Washington?
Opinions:
Majority - Justice Stevens (on merits); Justice O'Connor (on standard of review)
Yes, the Virginia Supreme Court's decision was both contrary to and an unreasonable application of clearly established federal law. First, interpreting 28 U.S.C. § 2254(d)(1), a state court decision is "contrary to" Supreme Court precedent if it applies a rule that contradicts the governing law or confronts materially indistinguishable facts and arrives at an opposite result. A decision involves an "unreasonable application" of law if the state court identifies the correct legal principle but unreasonably applies it to the facts of the case; an unreasonable application is different from a merely incorrect one. Here, the Virginia Supreme Court's decision was "contrary to" Strickland because it erroneously used Lockhart v. Fretwell to require a separate inquiry into fundamental fairness beyond Strickland's established prejudice test. The decision was also an "unreasonable application" of Strickland because it failed to evaluate the totality of the available mitigation evidence—including Williams's nightmarish childhood, borderline mental retardation, and positive prison conduct—and unreasonably concluded there was no reasonable probability that this evidence would have changed the sentencing outcome. The sheer volume and powerful nature of the omitted evidence undermines confidence in the death sentence.
Dissenting - Chief Justice Rehnquist
No, the Virginia Supreme Court’s decision did not result from an unreasonable application of Strickland. While counsel's performance may have been deficient, the aggravating evidence against Williams was overwhelming. He had engaged in a lifelong crime spree, committed a savage murder, and brutally assaulted other victims. Given this evidence of future dangerousness, it was not objectively unreasonable for the Virginia Supreme Court to conclude that evidence of Williams’s difficult childhood and low IQ would not have swayed the jury to impose a life sentence instead of death. The state court appropriately cited Strickland and its finding of no prejudice was a reasonable one that federal courts are bound to respect under AEDPA.
Analysis:
This landmark case provided the Supreme Court's first major interpretation of the standard of review under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The Court's holding established the crucial distinction between a state court decision being "contrary to" and an "unreasonable application of" federal law, setting the standard at "objective unreasonableness," which is more deferential than a simple "incorrect" standard. This decision significantly constrained the power of federal courts to grant habeas relief to state prisoners, making it substantially more difficult to challenge state court convictions and sentences on federal constitutional grounds. The ruling solidified AEDPA's goal of promoting finality and comity by requiring federal courts to defer to state court judgments unless they are egregiously flawed.
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