Facts
- Terry Williams was convicted in Virginia of robbery and capital murder and sentenced to death after the jury found a probability of future dangerousness.
- Trial counsel did not investigate or present available mitigating evidence at the capital sentencing phase.
- In state habeas proceedings, the trial judge found counsel ineffective for failing to discover and present significant mitigation and recommended resentencing.
- The Virginia Supreme Court rejected relief, reasoning that even if performance was deficient, Williams was not prejudiced and stating that Strickland prejudice was “modified” by Lockhart v. Fretwell.
- A federal district court granted habeas relief under 28 U.S.C. § 2254, identifying multiple categories of unpresented mitigation and finding a reasonable probability of a different sentencing outcome.
- The Fourth Circuit reversed, applying a restrictive view of AEDPA § 2254(d)(1) that would allow relief only when all reasonable jurists would agree the state court was unreasonable.
- The Supreme Court granted certiorari to review the AEDPA standard and the ineffective-assistance ruling.
Issues
- Whether Williams was denied effective assistance of counsel at capital sentencing under the Sixth Amendment due to counsel’s failure to investigate and present mitigating evidence.
- Whether the Virginia Supreme Court’s denial of relief was “contrary to, or involved an unreasonable application of, clearly established Federal law” under AEDPA, 28 U.S.C. § 2254(d)(1).
Decision
- The Supreme Court reversed the Fourth Circuit and remanded.
- The Court held Williams was deprived of effective assistance of counsel at sentencing.
- The Court held the Virginia Supreme Court’s decision was “contrary to” and/or an “unreasonable application” of clearly established Supreme Court law within the meaning of § 2254(d)(1).
- The Court rejected the Fourth Circuit’s “reasonable jurists would all agree” formulation as inconsistent with AEDPA’s objective unreasonableness standard.
- The Court concluded that substantial available mitigation—abuse and neglect in childhood, mental impairments and low intellectual functioning, and positive prison adjustment—was not presented due to deficient performance, and that there was a reasonable probability the sentence would have been different had it been presented.
Legal Principles
- Under AEDPA § 2254(d)(1), a state-court decision is “contrary to” clearly established Supreme Court precedent if it reaches an opposite legal conclusion or decides materially indistinguishable facts differently.
- Under AEDPA § 2254(d)(1), a state-court decision involves an “unreasonable application” when it identifies the governing rule but applies it to the facts in an objectively unreasonable manner; mere error is insufficient, but unanimity among reasonable jurists is not required.
- Strickland v. Washington requires (1) deficient performance and (2) prejudice shown by a reasonable probability that, but for counsel’s errors, the result would have been different.
- Lockhart v. Fretwell does not replace or narrow Strickland’s reasonable-probability prejudice standard; treating it as a modification that alters the governing test is inconsistent with clearly established law.
- In capital sentencing, failure to investigate and present readily available mitigating evidence can constitute deficient performance, and prejudice is evaluated by considering the totality of mitigation against the aggravating case.
Conclusion
The Supreme Court held that counsel’s failure to investigate and present significant mitigating evidence rendered Williams’ capital sentencing constitutionally unreliable and that the state court’s denial of relief rested on a rule and application inconsistent with Strickland as required by AEDPA § 2254(d)(1).