## Facts

- Jeffrey Timothy Landrigan, already imprisoned for second-degree murder, escaped and later killed a person during a burglary.
- He was convicted in Arizona of felony murder and faced capital sentencing.
- Defense counsel sought to present mitigating evidence through testimony from Landrigan’s ex-wife and biological mother about his troubled background and substance abuse.
- Landrigan instructed counsel not to present those witnesses; at his direction, the witnesses refused to testify.
- In court, Landrigan repeatedly stated he did not want mitigating evidence presented and made statements indicating he accepted a death sentence.
- The sentencing judge found two statutory aggravating circumstances and found some mitigation, but concluded aggravation outweighed mitigation and imposed a death sentence.
- On state post-conviction review, Landrigan alleged ineffective assistance at sentencing for failure to investigate and present additional mitigating evidence (including a claimed genetic predisposition to violence); the state court rejected the claim based on Landrigan’s instructions to present no mitigation.
- In federal habeas proceedings under 28 U.S.C. § 2254, the district court denied an evidentiary hearing and denied relief; the Ninth Circuit (en banc) reversed and ordered a hearing.

## Issues

1. Whether, under AEDPA and § 2254(d)’s deference to state-court determinations, the federal district court abused its discretion by denying an evidentiary hearing on Landrigan’s ineffective-assistance claim.
2. Whether Landrigan could satisfy Strickland’s prejudice requirement given his express refusal to allow mitigation at sentencing.

## Decision

- The Supreme Court reversed the Ninth Circuit and reinstated the district court’s denial of an evidentiary hearing and habeas relief.
- The Court held the district court did not abuse its discretion because the existing record showed Landrigan instructed counsel not to present mitigating evidence.
- The Court concluded that, in light of Landrigan’s waiver and obstruction of mitigation, additional mitigation developed at a hearing would not establish entitlement to federal habeas relief under AEDPA and Strickland.

## Legal Principles

- Under AEDPA, federal habeas relief is unavailable unless the state court’s adjudication was contrary to, or an unreasonable application of, clearly established federal law, or rested on an unreasonable determination of facts.
- In deciding whether to grant a federal habeas evidentiary hearing, a district court must consider AEDPA’s limits and whether a hearing could develop facts that, if true, would entitle the petitioner to relief.
- A district court need not hold an evidentiary hearing when the existing record refutes the petitioner’s allegations or otherwise precludes habeas relief.
- Under Strickland, a capital-sentencing ineffective-assistance claim requires a showing of prejudice; a defendant’s express instructions not to present mitigation may defeat prejudice where the defendant would have prevented mitigation regardless of further investigation.

## Conclusion

The Court held that AEDPA deference and the sentencing record supported denying an evidentiary hearing because Landrigan’s own refusal to allow mitigating evidence foreclosed a showing that additional investigation would have changed the sentence.


Schriro v. Landrigan, 550 U.S. 465 (2007)