## Facts

- Annie Lester, an 80-year-old woman, was killed in her home in October 1996; an autopsy found 22 stab wounds, head trauma from a blunt object, and a crushed throat consistent with strangulation or forceful impact.
- A blood trail ran from the kitchen to the bedroom where her body was found; the bedroom was ransacked and her clothing was disarranged.
- Evidence linked James Edward Reid to the crime: he was driven to Lester’s home that morning after buying wine; later he was seen intoxicated and covered in blood; blood on his clothing was consistent with Lester’s DNA; his fingerprint in blood was found on a telephone in the bedroom; his saliva was found on a cigarette butt; and handwriting evidence tied him to the scene.
- Reid asserted he could not remember the killing but entered an Alford plea to capital murder, attempted rape, and attempted robbery.
- After a bench sentencing hearing, the trial judge imposed the death penalty under Virginia’s “vileness” aggravator, finding aggravated battery and depravity of mind based on the injuries and circumstances.

## Issues

1. Whether a federal habeas court must assume a state court applied an unconstitutional ineffective-assistance standard when the state court’s denial is summary and unreasoned.
2. Whether the state court unreasonably applied Strickland in rejecting claims that counsel were ineffective in investigating/presenting mitigation and advising the Alford plea.
3. Whether the death sentence violated the Eighth and Fourteenth Amendments because Virginia courts allegedly failed to consider mitigation adequately or misapplied the “vileness” aggravator.

## Decision

- The Fourth Circuit affirmed the district court’s denial of Reid’s 28 U.S.C. § 2254 petition.
- The court treated the state court’s summary denial as a merits adjudication entitled to AEDPA deference and declined to infer use of an unconstitutional standard from the absence of reasoning.
- The court held that the state court’s rejection of Reid’s ineffective-assistance claims was not contrary to, nor an unreasonable application of, clearly established federal law.
- The court rejected challenges to the capital sentencing determination, concluding the vileness finding and mitigation consideration were constitutionally sufficient on the record.

## Legal Principles

- A state court’s unreasoned denial may constitute an adjudication on the merits and is reviewed under AEDPA’s deferential standards.
- Under 28 U.S.C. § 2254(d)(1), federal habeas relief is available only if the state court decision is contrary to, or an unreasonable application of, clearly established Supreme Court precedent; mere error is insufficient.
- Ineffective-assistance claims are governed by Strickland’s deficient-performance and prejudice requirements; under AEDPA, review of a state Strickland determination is highly deferential.
- For plea-based ineffective-assistance claims, the petitioner must show a reasonable probability that, with competent advice, he would have rejected the plea and insisted on trial.
- A death sentence based on a state aggravating factor does not violate the Eighth Amendment where the factor is applied to conduct meeting the statutory standard and the record supports that application, and where mitigation is considered.

## Conclusion

The Fourth Circuit left Reid’s conviction and death sentence intact, holding that AEDPA required deference to the state court’s summary merits denial and that Reid failed to show an unreasonable application of Strickland or a constitutional defect in the vileness-based capital sentencing decision.


Reid v. True, 349 F.3d 788 (4th Cir. 2003)