Andrus v. Texas

Background

A Texas man condemned to death for a 2008 carjacking and related killings said his trial lawyer never looked for or presented evidence about his childhood. The man grew up with extreme neglect, a mother who sold drugs and prostituted herself, stints in a traumatic juvenile facility, heavy psychotropic medication, and suicide attempts. At trial the defense largely conceded guilt, presented minimal mitigation, and called a hostile mother as a witness.

Reasoning

The Court examined whether the lawyer’s performance fell below the level the Constitution requires and whether that performance hurt the client’s chance of avoiding death. The Court concluded the lawyer’s investigation was grossly inadequate and therefore constitutionally deficient under the standard for ineffective assistance. Because the state high court’s unexplained one-sentence denial left uncertainty about whether it properly evaluated whether the deficient performance prejudiced the sentence, the Supreme Court vacated that decision and sent the case back for the state court to decide the prejudice question in the first instance.

Real world impact

The ruling does not itself change the death sentence. Instead, it forces the Texas court to reexamine whether failing to present abundant, readily available childhood and mental-health evidence likely changed at least one juror’s view about imposing death. If the state court finds prejudice, the defendant could receive a new sentencing proceeding.

Dissents or concurrances

A dissent argued the state court already decided there was no prejudice and criticized the Supreme Court for ordering further review, defending the original denial of relief.