Strickland v. Washington
Headline: Court adopts a two-part test for ineffective-lawyer claims, requires reasonableness plus proof the outcome likely would differ, and upholds this defendant’s death sentence because omitted evidence was unlikely to change the result.
Holding:
- Establishes two-part test: unreasonable performance and reasonable probability of different result.
- Gives judges reason to defer to strategic lawyer decisions in criminal cases.
- Applies the same standard to capital sentencing, limiting reversals without strong prejudice.
Summary
Background
A man who pleaded guilty to three brutal, closely linked crimes including three murders was sentenced to death after a bench sentencing. His lawyer chose not to seek psychiatric testing, did not develop character witnesses, and relied on the defendant’s plea statements in mitigation. State courts affirmed the convictions and sentences. The defendant then sought federal habeas relief, and the Court of Appeals ordered further review under newly announced standards.
Reasoning
The Court took up whether the Constitution requires a different test for claims that a lawyer’s help was ineffective. It announced a clear two-part test: (1) the lawyer’s performance must have been objectively unreasonable, and (2) the defendant must show a reasonable probability that the result would have been different but for the mistakes — enough to undermine confidence in the outcome. The Court emphasized deference to sensible strategic choices by lawyers and said capital sentencing is like a trial for these purposes. Applying those rules here, the Court found counsel’s strategy reasonable and concluded any omitted mitigation evidence was unlikely to change the judge’s decision.
Real world impact
The ruling sets a national standard for judging lawyer errors in criminal cases. It makes clear courts must give lawyers wide latitude for strategy, but also requires defendants to show a meaningful chance the result would have changed. The decision applies to death-penalty sentencing and federal habeas review.
Dissents or concurrances
Justice Marshall dissented, arguing the standard is too vague and that counsel’s failure to investigate was unreasonable. Justice Brennan concurred in part but would have vacated the death sentence.
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