Facts
- Lionel E. Gentry was convicted in California state court of assault with a deadly weapon for stabbing his girlfriend, Tanaysha Handy.
- Gentry claimed the stabbing was accidental during a confrontation involving a drug dealer.
- Handy testified she recalled being stabbed but not the details; the prosecution impeached her with prior testimony that Gentry grabbed her throat and stabbed her twice.
- Security guard Albert Williams testified he saw Gentry swing his hand with an object into Handy’s side, causing her to scream; he gave inconsistent descriptions of the lighting conditions.
- Gentry testified and falsely minimized his prior convictions; the record showed multiple felony convictions.
- In closing argument, the prosecutor attacked Gentry’s credibility and appealed to sympathy for Handy.
- Defense counsel gave a brief, candid closing stressing uncertainty about what happened, focusing the jury on reasonable doubt, and challenging Williams’s reliability based on inconsistencies.
Issues
- Whether, on federal habeas review, the Ninth Circuit properly found ineffective assistance of counsel based on trial counsel’s closing argument.
- Whether the state courts’ rejection of the ineffective-assistance claim was an objectively unreasonable application of clearly established federal law under Strickland and 28 U.S.C. § 2254(d).
Decision
- The Supreme Court granted certiorari and reversed the Ninth Circuit in a per curiam decision.
- The Court held that the state courts’ conclusion that counsel’s closing argument was not constitutionally ineffective was not objectively unreasonable.
- The Court ruled that the Ninth Circuit failed to apply the required deference to counsel’s strategic choices and to the state courts’ Strickland determination under AEDPA.
- Habeas relief was therefore improper.
Legal Principles
- Ineffective assistance requires deficient performance and prejudice; courts apply a strong presumption that counsel acted within the wide range of reasonable professional assistance.
- The Sixth Amendment right to effective assistance extends to closing argument, but summation involves broad strategic choice; courts must be particularly cautious before treating a closing strategy as constitutionally deficient.
- Under 28 U.S.C. § 2254(d), a federal habeas court may grant relief only if the state court decision was contrary to, or involved an unreasonable application of, clearly established Supreme Court precedent; it is not enough that the federal court would have reached a different result.
- In state-prisoner habeas ineffective-assistance claims, review is doubly deferential: deference to counsel’s strategy under Strickland and deference to the state court’s application of Strickland under AEDPA.
Conclusion
The Court reinstated the state conviction, holding that federal habeas courts may not second-guess reasonable tactical choices in closing argument where the state courts’ rejection of a Strickland claim falls within the range of reasonable adjudication required by AEDPA.