Hinton v. Alabama
The Supreme Court ruled that a death-row inmate's trial lawyer performed unconstitutionally poorly because he mistakenly believed state law capped expert-witness funding at $1,000, when in fact he could have asked for more money to hire a better ballistics expert.
The Court sent the case back to Alabama's courts to decide, under the correct legal standard, whether that failure actually changed the outcome of the trial — a question no court had properly answered.
How it got here: Alabama courts denied Hinton's ineffective-assistance claim after post-conviction proceedings and appeals; Hinton then asked the Supreme Court to review that decision.
The Case in Depth
What happened
Anthony Ray Hinton was convicted and sentenced to death for two 1985 restaurant robbery-murders in Birmingham, Alabama, based almost entirely on forensic testimony linking bullets from the crimes to a revolver found at his home. His trial lawyer, believing funding for a defense expert was capped at $1,000, hired the only expert he could afford, whose testimony was discredited at trial, including admissions about limited experience and difficulty using lab equipment.
The question before the Court
Did a death-row inmate's trial lawyer provide constitutionally inadequate help by hiring a weak firearms expert only because he wrongly believed funding was capped at $1,000?
Why it matters
The ruling reinforces that defense lawyers, especially in capital cases, must actually know the funding rules available to them rather than assume limits that don't exist. It puts pressure on Alabama courts to reexamine whether a weak forensic expert may have contributed to a wrongful death sentence, and it signals to trial lawyers nationwide that ignorance of available resources can amount to a Sixth Amendment violation.
What changes now
The case returns to the Alabama courts, which must now determine, under the correct legal standard, whether the attorney's deficient performance was prejudicial — that is, whether a properly funded expert likely would have changed the jury's verdict. This is not a final resolution of Hinton's conviction or sentence; if the prejudice inquiry favors Hinton, he could receive a new trial.
What this does not decide
The Court explicitly did not decide whether Hinton's original expert was simply less qualified than an ideal expert would have been, nor did it rule on the comparative qualifications of experts generally. It only found the lawyer's failure to seek available funding unreasonable, leaving the prejudice question for Alabama courts to resolve.
How the Court got there
The legal reasoning, step by step
- The Court applied the two-part test from Strickland v. Washington for ineffective assistance of counsel: first asking whether the lawyer's performance fell below an objective standard of reasonableness, and second whether that poor performance likely changed the trial's outcome.
- On the first prong, the Court found it unreasonable for Hinton's lawyer to stop seeking expert funding based on a mistaken belief that Alabama law capped reimbursement at $1,000, when the law had actually been amended over a year before the arrest to allow reimbursement for any reasonably incurred expenses.
- The Court emphasized that a lawyer's ignorance of a legal point central to the case, combined with failing to do basic legal research on it, is a textbook example of deficient performance under Strickland — distinct from a reasoned strategic choice about which expert to hire.
- The Court clarified that its ruling was not about whether a better-qualified expert existed, but solely about the lawyer's failure to understand and pursue the funding resources actually available to him under state law.
- Turning to the second prong, the Court found that no state court had yet properly asked whether there was a reasonable probability that a better-funded expert could have created reasonable doubt in the jury's mind, since prior rulings focused only on whether the hired expert was minimally qualified.
Doctrinal impact
Cases affected by this decision
Reaffirms Strickland v. Washington (466 U. S. 668)
The Court applied and relied on Strickland's two-part test as the controlling standard for ineffective assistance claims.