Strickland V. Washington Ineffective Assistance Of Counsel
What Is Strickland v. Washington? (1984)
Facts:
David Washington claimed his lawyer gave ineffective help during his murder trial, which led to his conviction.
Legal Question:
What is the standard for proving a claim of ineffective assistance of counsel under the Sixth Amendment?
Supreme Court Holding:
To prove ineffective assistance, a defendant must show:
Deficient Performance: Counsel’s performance fell below an objective standard of reasonableness.
Prejudice: There is a reasonable probability that, but for counsel’s errors, the result would have been different.
Key Points of the Strickland Standard
Courts give deference to lawyers’ strategic decisions.
Both prongs (deficient performance and prejudice) must be met.
Applies to all stages of criminal proceedings.
Important Related Cases
1. Strickland v. Washington (1984)
Established the two-prong test for ineffective assistance.
Emphasizes both poor performance and actual prejudice.
2. Rompilla v. Beard (2005)
Facts:
Counsel failed to review a key prior conviction file that could have been used to argue against the death penalty.
Holding:
Counsel was ineffective because failing to investigate clearly prejudiced the defendant.
Significance:
Shows failure to investigate important evidence can be ineffective assistance.
3. Wiggins v. Smith (2003)
Facts:
Defense counsel failed to investigate and present mitigating evidence of defendant’s abusive childhood in a capital case.
Holding:
Counsel was ineffective under Strickland for inadequate investigation and failure to present key mitigation.
Significance:
Expands on how preparation and investigation relate to effective counsel.
4. Florida v. Nixon (2004)
Facts:
Counsel conceded guilt without defendant’s explicit consent.
Holding:
Counsel’s performance was not deficient because conceding guilt was a reasonable strategy.
Significance:
Shows deference to strategic decisions unless clearly unreasonable.
5. Bobby v. Van Hook (2009)
Facts:
Counsel failed to present expert testimony about defendant’s intellectual disability.
Holding:
Counsel was not ineffective because the state court’s evaluation of performance was reasonable.
Significance:
Reinforces that courts must defer to reasonable strategic choices.
6. Kimmelman v. Morrison (1986)
Facts:
Counsel failed to investigate evidence that could have excluded a key witness.
Holding:
Counsel was ineffective; inadequate investigation prejudiced the defense.
Significance:
Emphasizes importance of thorough investigation.
Summary Table
| Case | Issue | Outcome/Rule | Importance |
|---|---|---|---|
| Strickland v. Washington (1984) | Established 2-prong test for ineffective assistance | Deficient performance + prejudice required | Foundation of ineffective assistance law |
| Rompilla v. Beard (2005) | Failure to review crucial evidence | Counsel ineffective due to failure to investigate | Duty to investigate key evidence |
| Wiggins v. Smith (2003) | Failure to investigate and present mitigation | Counsel ineffective due to inadequate preparation | Effective counsel requires thorough investigation |
| Florida v. Nixon (2004) | Counsel conceded guilt as strategy | No ineffective assistance if reasonable strategy | Deference to strategy decisions |
| Bobby v. Van Hook (2009) | Failure to present expert testimony | Counsel not ineffective due to reasonable judgment | Courts defer to reasonable decisions |
| Kimmelman v. Morrison (1986) | Failure to investigate evidence | Counsel ineffective due to prejudice | Investigation is critical |
Key Takeaways
Ineffective assistance requires both poor performance and showing it affected the case outcome.
Courts strongly defer to attorney strategy unless clearly unreasonable.
Failing to investigate or present key evidence is a common ground for claims.
Not every lawyer mistake counts; must cause prejudice.
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