Dunn v. Reeves

Background

Matthew Reeves, convicted of murdering a man who towed his broken-down car, was sentenced to death after a short penalty-phase presentation. His trial lawyers sought funding for a neuropsychologist, obtained many records, but apparently did not hire the expert before sentencing. Years later Reeves sought state postconviction relief, calling an expert who said Reeves met the criteria for intellectual disability; the State’s expert disagreed. Reeves did not call his trial lawyers to explain their choices at the state hearing.

Reasoning

The narrow question was whether the Alabama Court of Criminal Appeals had violated clearly established federal law by denying Reeves’ claim that his lawyers were constitutionally ineffective for not hiring an expert. The Supreme Court explained that strategic decisions by lawyers get a strong presumption of reasonableness and that a defendant bears the burden to overcome that presumption. Because the record was silent about counsel’s reasons—largely because Reeves did not call them—the Alabama court’s denial was a permissible, case-specific determination. The Eleventh Circuit had misread the Alabama opinion as adopting a blanket rule and failed to give required deference; the Supreme Court reversed and remanded for further proceedings consistent with its opinion.

Real world impact

The decision emphasizes that federal courts owe deference to reasonable state-court findings about lawyer strategy, especially when the record lacks testimony from trial counsel. It makes it harder for defendants to succeed on federal review of ineffective-assistance claims without offering evidence explaining counsel’s choices. The Supreme Court reversed the appeals court and sent the case back, so the ruling does not decide every factual question on the merits.

Dissents or concurrances

Justice Sotomayor dissented, arguing the Alabama court had applied a per se rule requiring counsel’s testimony contrary to Strickland and that the Eleventh Circuit was correct to reverse.