Facts
- Kevin Wiggins was convicted in Maryland of capital murder in 1989 and elected jury sentencing.
- Defense counsel sought to structure sentencing to first dispute whether Wiggins was the actual killer and to present mitigation only if necessary.
- Counsel told the jury it would hear about Wiggins’s “difficult life,” but presented no mitigating evidence at the penalty phase.
- Counsel’s mitigation investigation relied primarily on a presentence investigation, a psychological report, and limited social-services records, without pursuing indications of abuse and instability.
- State funding was available to develop a comprehensive social history, but counsel did not secure such an investigation.
- In state postconviction proceedings, new counsel presented detailed evidence that Wiggins suffered severe physical and sexual abuse, repeated foster placements, neglect, abandonment, and homelessness.
- State courts denied relief, treating trial counsel’s penalty-phase choices as a reasonable strategy.
- A federal district court granted habeas relief; the Fourth Circuit reversed; the Supreme Court granted review.
Issues
- Whether trial counsel provided ineffective assistance at capital sentencing by failing to investigate and present readily available mitigation evidence, under Strickland’s performance and prejudice standards.
- Whether, under 28 U.S.C. § 2254(d)(1), the state court’s rejection of the ineffective-assistance claim was an unreasonable application of clearly established federal law.
Decision
- The Supreme Court reversed the Fourth Circuit and held that counsel’s sentencing performance violated the Sixth Amendment.
- The Court found deficient performance because counsel’s mitigation investigation was inadequate under prevailing professional norms and did not reasonably support the decision to forgo a mitigation presentation.
- The Court found prejudice because there was a reasonable probability that at least one juror would have chosen a different sentence if the jury had heard the substantial mitigation evidence.
- The Court concluded that the state court’s contrary ruling was an unreasonable application of Strickland under AEDPA.
Legal Principles
- Effective capital representation requires a reasonable investigation into mitigating evidence or a reasonable, informed decision that further investigation is unnecessary.
- Deference to “strategic” choices applies only when the choice is grounded in an adequate investigation of the relevant facts and options.
- Prevailing professional norms, including the ABA Guidelines for capital defense, may be used as guidance in assessing reasonableness of counsel’s performance.
- Prejudice at capital sentencing may be shown where omitted mitigation is powerful and noncumulative and could reasonably affect the weighing of aggravating and mitigating factors, including by influencing a single juror.
- On federal habeas review, relief is available when the state court unreasonably applies clearly established Supreme Court precedent, not merely when a federal court would decide differently.
Conclusion
The Court held that capital counsel’s failure to conduct a competent mitigation investigation and present compelling evidence of severe childhood abuse and deprivation constituted ineffective assistance, and that the state court unreasonably applied Strickland in denying relief under AEDPA.