Strickland v. Washington
| Strickland v. Washington | |
|---|---|
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| Argued January 10, 1984 Decided May 14, 1984 |
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| Full case name | Strickland, Superintendent, Florida State Prison, v. Washington |
| Citations | 466 U.S. 668 (more)
466 U.S. 668; 104 S. Ct. 2052; 80 L. Ed. 2d 674 (1984)
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| Prior history | Writ of habeas corpus denied by the United States District Court for the Southern District of Florida; reversed by the Eleventh Circuit, 693 F.2d 1243 (11th Cir. 1982); cert. granted, 462 U.S. 1105 (1983) |
| Holding | |
| To obtain relief because of ineffective assistance of counsel, a criminal defendant must show both that counsel's performance fell below an objective standard of reasonableness and that counsel's deficient performance gives rise to a reasonable probability that if counsel had performed adequately, the result of the proceeding would have been different. | |
| Court membership | |
| Case opinions | |
| Majority | O'Connor, joined by Burger, White, Blackmun, Powell, Rehnquist, Stevens |
| Concur/dissent | Brennan |
| Dissent | Marshall |
| Laws applied | |
| U.S. Const. amend. VI | |
Strickland v. Washington, 466 U.S. 668 (1984), was a decision by the Supreme Court of the United States that established the standard for determining when a criminal defendant's Sixth Amendment right to counsel is violated by that counsel's inadequate performance.
The Court, in a decision by Justice O'Connor, established a two-part test for an ineffective assistance of counsel claim: a criminal defendant must show two things:
The decision was a compromise by the majority in which the varying "tests for ineffective performance of counsel" among the federal circuits and state supreme courts were forced into a singular middle ground test. State governments are free to create a test even more favorable to an appellant.
David Washington pleaded guilty in a Florida trial court to an indictment that included three capital murder charges. During the plea colloquy, Washington told the trial judge that although he had committed a string of burglaries, at the time of his criminal spree, he was under extreme stress caused by his inability to support his family. The trial judge told Washington that he had "a great deal of respect for people who are willing to step forward and admit their responsibility."
In preparing for the sentencing hearing, defense counsel spoke with Washington about his background but did not seek out character witnesses or request a psychiatric examination. The counsel's decision not to present evidence concerning Washington's character and emotional state reflected his judgment that it was advisable to rely on the plea colloquy for evidence as to such matters, thus preventing the state from cross-examining Washington and from presenting psychiatric evidence of its own. Counsel did not request a presentence report because it would have included Washington's criminal history and thereby would have undermined the claim of no significant prior criminal record.
Finding numerous aggravating circumstances and no mitigating circumstance, the trial judge sentenced Washington to death on each of the murder counts. The Florida Supreme Court affirmed Washington's sentences on direct appeal.
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