| Venue: | SCOTUS |
| Facts: | Williams confesses to a bunch of crimes, including murder. Absolutely asinine lawyering at sentencing-- just no help at all. |
| Posture: | Convicted of robbery and capital murder. VA SC affirms. Files state habeas petition alleging ineffective counsel. Court finds that they were ineffective at sentencing, and recommends a rehearing. VA SC declines to accpet that recommendation: sure they were ineffective, but it wasn't so prejudicial as to warrant relief. Time for federal habeas: district court finds the death sentence to be constitutionally infirm. Ct. App. reverses. |
| Issue: | Was Williams's right to effective assistance of counsel violated, and was the VA SC's refusal to set aside his death sentence contrary to clearly established law or an unreasonable application thereof? |
| Holding: | Yes, and yes. Reversed. |
| Rule: | The AEDPA § 2254(d)(1) standard, as interpreted by O'Connor. |
| Reasoning: | Let's go to the rule. The "clearly established law determined by the
Supreme Court of the United States" clause is pretty straigtforward.
Even on habeas, federal courts have an independent obligation
to say what the law is, and this doesn't change that. All we're
doing here is reiterating what we said in Teague about
habeas not being a platform for evoking novel rules of
law. AEDPA just qualifies Teague by stating the acceptable
source of the clearly established law.
The "contrary to, or unreasonable application of" requirement comes from O'Connor's concurrence. "Contrary to" means that either the court applied a rule that contradicts governing law, or the court confronted facts materially indistinguishable from SCOTUS precedent and got a different result. "Unreasonable application" means that the court got the right rule, but applied it to the facts unreasonably or that the court either unreasonably extended or refused to extend a rule based on the facts. So note that "correctness" is not a consideration here: they could get the wrong result, just as long as it's not unreasonably wrong. OK, so is the rule Williams wants clearly established? Yes: Strickland is SCOTUS precedent, and it defines the ineffective assistance standard. The VA court got Strickland and Lockhart intermingled-- Lockhart (saying that the outcome alone does not determine whether there was prejudice) does not supercede Strickland. Fine, so was it unreasonable? Well, yes: both did it get the rule wrong and also failed to evaluate the totality of the evidence. |
| Dicta: | Rhenquist (dissenting): It's unreasonable to assume that the mitigation evidence would have persuaded the jury to find differently. |