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
- 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.
- Whether Washington’s counsel performed deficiently at capital sentencing by limiting investigation and mitigation evidence.
- 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.