Strickland v. Washington

1984

Venue: SCOTUS

Facts: Horrible crime spree. The attorney feels hopeless because his client keeps confessing things.

Posture: Guilty plea. Multiple death sentences. Appeal for ineffective assistence fails in FL SC. Habeas petition denied in federal district court. Affirmed in part, vacated in part, and remanded by 5th Cir.

Issue: Should the federal district court have issued the habeas writ?

Holding: No. Affirmed.

Rule: In order for there to be ineffective assistance of counsel there needs to be:
  1. Deficient performance
  2. Prejudice as a result

Reasoning: We only care about errors that might preclude reaching a just result.

Dicta: Brennan, dissenting: the death penalty raises the standards of performance.

Marshall, dissenting: this standard is too malleable. Plus we're not just trying to prevent innocent people from being convicted-- even the guilty are entitled to a fair trial.