## Facts

- David Leroy Washington pleaded guilty in Florida state court to charges including three capital murders arising from a ten-day crime spree involving multiple violent offenses.
- Washington waived a sentencing jury and elected judge sentencing, against counsel’s advice.
- At sentencing, defense counsel did not present character witnesses, seek a psychiatric evaluation, or request a presentence investigation report.
- Counsel pursued a limited mitigation strategy based on Washington’s plea colloquy and some family information, seeking to avoid harmful cross-examination, adverse mental-health evidence, or fuller exposure of Washington’s criminal conduct.
- The trial judge found multiple statutory aggravating circumstances, found no mitigating circumstances, and imposed death sentences; the Florida Supreme Court affirmed.
- On state postconviction review, Washington claimed ineffective assistance at sentencing for failure to investigate and present mitigating evidence; relief was denied and affirmed.
- In federal habeas, the district court found counsel made judgment errors but found no prejudice and denied relief; the Eleventh Circuit reversed and applied a “reasonably effective assistance” standard under the totality of the circumstances.
- The Supreme Court granted review to resolve the governing Sixth Amendment standard for ineffective-assistance claims.

## Issues

1. What standard governs a claim that counsel’s performance violated the Sixth Amendment right to effective assistance, requiring reversal of a conviction or death sentence.
2. Whether Washington’s counsel performed deficiently at capital sentencing by limiting investigation and mitigation evidence.
3. Whether any asserted deficiencies created sufficient prejudice to warrant habeas relief.

## Decision

- The Supreme Court reversed the Eleventh Circuit and reinstated the denial of habeas relief.
- The Court adopted a two-prong test requiring proof of (1) deficient performance and (2) prejudice.
- The Court held Washington failed to establish constitutionally deficient performance and, independently, failed to show prejudice because the aggravating case was overwhelming and the omitted mitigation did not create a reasonable probability of a different sentence.
- Justice Brennan concurred in part and dissented in part, declining to affirm a death sentence based on his Eighth Amendment views.
- Justice Marshall dissented, disputing the majority’s deference and concluding counsel was ineffective on these facts.

## Legal Principles

- A Sixth Amendment ineffective-assistance claim requires proof that (1) counsel’s performance fell below an objective standard of reasonableness under prevailing professional norms and (2) the deficient performance prejudiced the defense.
- Courts must apply highly deferential review of attorney performance and presume counsel acted within the wide range of reasonable professional assistance; strategic choices are ordinarily protected from hindsight review.
- Prejudice requires a reasonable probability that, but for counsel’s unprofessional errors, the result would have been different; a reasonable probability is sufficient to undermine confidence in the outcome and need not satisfy a “more likely than not” standard.
- A defendant must prove both prongs; failure on either prong defeats the claim, and courts may resolve claims on prejudice grounds without deciding performance.

## Conclusion

The Court established the controlling Sixth Amendment framework for ineffective-assistance claims by requiring defendants to prove both objectively unreasonable representation and resulting prejudice measured by a reasonable probability of a different outcome; applying that test, the Court upheld Washington’s death sentence and denied habeas relief.


Strickland v. Washington, 466 U.S. 668 (1984)