Strickland v. Washington

Questions Presented

1. What constitutional standard governs claims that defense counsel provided ineffective assistance?
2. Does the ineffective-assistance standard apply to a capital sentencing proceeding that is sufficiently adversarial and structured like a trial?
3. What showing of deficient performance and prejudice must a convicted defendant make to obtain reversal of a conviction or death sentence?
4. How should courts evaluate counsel's investigative and strategic decisions?
5. How do ineffective-assistance standards apply in federal collateral proceedings and in federal habeas review of state-court judgments?
6. Whether Washington demonstrated deficient performance or prejudice sufficient to invalidate his death sentences.

Holdings

1. The Sixth Amendment right to counsel is the right to effective assistance of counsel, and the benchmark is whether counsel's conduct undermined the proper functioning of the adversarial process so that the proceeding cannot be relied upon as producing a just result.
2. The same ineffective-assistance principles apply to a capital sentencing proceeding that is sufficiently like a trial in adversarial format and has standards governing the sentencer's decision.
3. A defendant claiming ineffective assistance must show that counsel's representation fell below an objective standard of reasonableness under prevailing professional norms and the circumstances of the case.
4. Counsel has a duty to make reasonable investigations or to make a reasonable decision that particular investigations are unnecessary; strategic choices made after reasonable investigation or reasonable professional judgment are entitled to substantial deference.
5. The defendant must show a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different; a reasonable probability is one sufficient to undermine confidence in the outcome.
6. A court need not determine whether counsel's performance was deficient before examining prejudice and may reject an ineffective-assistance claim solely for lack of sufficient prejudice.
7. Washington failed to establish ineffective assistance because counsel's sentencing strategy was within the range of professionally reasonable judgment and, in any event, the omitted evidence did not create a reasonable probability that the death sentences would have been avoided.
8. The same ineffective-assistance principles apply on direct appeal, in motions for a new trial, and in federal collateral proceedings. In federal habeas review of a state judgment, the effectiveness inquiry is a mixed question of law and fact, while state factual findings remain subject to the applicable statutory deference.

Key quotations

Factual background

David Leroy Washington committed three groups of crimes during a ten-day period, including three brutal murders, and confessed after surrendering to police. He pleaded guilty to all charges and waived an advisory jury for capital sentencing. At sentencing, counsel relied primarily on the plea colloquy and did not seek additional character evidence, a psychiatric examination, or a presentence report because counsel believed those matters could be harmful and the aggravating circumstances were overwhelming. The trial judge found numerous aggravating circumstances and no, or only insignificant, mitigating circumstances and imposed three death sentences.

Procedural history

Washington pleaded guilty in Florida state court to three capital murders and other offenses and received three death sentences. The Florida Supreme Court affirmed on direct appeal and later affirmed denial of state collateral relief. The federal District Court denied habeas relief after an evidentiary hearing, finding no prejudice from counsel's alleged errors. The Court of Appeals reversed and remanded, and the Supreme Court reversed the Court of Appeals.