Aldrich v. Wainwright, Secretary, Florida Department of Corrections

Background

A man named Levis Leon Aldrich was charged with killing Robert Ward, a restaurant night manager. Police found Ward shot and the restaurant’s safe emptied. Officers later stopped Aldrich, who had over $500 and a prison release receipt. The shotgun that killed Ward was traced to Charles Strickland, who said he lent it to Aldrich and later helped recover and hide the parts. No physical evidence tied Aldrich to the crime. Aldrich was tried, testified in his own defense, and at his request presented no mitigating evidence; a jury recommended death and the trial court imposed a death sentence. State and federal appeals and post-conviction petitions were denied before the Supreme Court received his request for review.

Reasoning

The Supreme Court declined to hear the case and denied the petition for review. The lower courts had found trial counsel was poorly prepared and failed to investigate, depose witnesses, or examine exhibits; but the Court of Appeals concluded Aldrich had not shown the required prejudice from that poor performance. Justice Marshall dissented from the denial, arguing the evidence against Aldrich was weak and that counsel’s failures undermined confidence in the trial result.

Real world impact

Because the Supreme Court refused review, the conviction and death sentence remain in effect and the lower-court rulings stand. This decision is not a ruling on the merits of the ineffective-assistance claim by the high Court. The case highlights how failures in trial preparation can determine life-or-death outcomes in capital trials.

Dissents or concurrances

Justice Marshall, joined by Justice Brennan, would have granted review and, on his view of the law, would vacate the death sentence or at least order relief because of counsel’s inadequate preparation.