Bonin v. California
Headline: Court denied review and left the conviction and death sentence in place, rejecting a dissent that argued the death penalty is always cruel and counsel conflicts required a new trial.
Holding: The Court denied review and left the conviction and death sentence in place, rejecting a dissent that argued the death penalty is always cruel and counsel conflicts required a new trial.
- Leaves Bonin’s conviction and death sentence in place.
- Highlights judges’ duty to investigate apparent lawyer conflicts before trial.
- Suggests courts should presume harm from actual conflicts, easing new-trial relief.
Summary
Background
William George Bonin was tried for multiple murders and robberies. He asked to replace his longtime lawyer with William Charvet just before trial. The prosecutor objected because Charvet had previously represented James Munro, an alleged accomplice and key witness, and because Charvet likely had a contract giving him rights to publish Bonin’s life story. The trial judge first denied the switch, then allowed Charvet to represent Bonin without fully addressing those conflicts and without obtaining a waiver from Bonin. Bonin was convicted on ten counts and sentenced to death, and the California Supreme Court affirmed the result.
Reasoning
Justice Marshall would have granted review to decide two simple questions: when must a judge investigate a possible lawyer conflict, and whether a defendant must prove that a proven conflict actually hurt the lawyer’s performance. He argued that a judge must ask further questions whenever the court knows or reasonably should know a conflict might exist. He warned that a book-deal could tempt a lawyer to favor publicity over a client’s interests. Marshall said that once an actual conflict is shown, courts should presume it harmed the defense rather than forcing defendants to prove the harm.
Real world impact
Because Bonin faces execution, Marshall stressed the urgency of these questions. If his view prevailed, defendants whose lawyers have clear, actual conflicts would more easily get new trials. The opinion also underscores that proving how a conflict affected an attorney is often impossible on appeal, so presuming harm protects defendants. As issued, the denial of review leaves Bonin’s conviction and sentence in place while the legal dispute continues.
Dissents or concurrances
Justice Marshall, joined by Justice Brennan, dissented from the decision not to review the case and explained these points in detail, urging a new trial absent a valid waiver.
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