Strickland V. Washington - Background

Background

David Washington pled guilty in a Florida trial court to an indictment that included three capital murder charges. In the plea colloquy, Washington told the trial judge that, although he had committed a string of burglaries, at the time of his criminal spree he was under extreme stress caused by his inability to support his family. The trial judge told Washington that he had "a great deal of respect for people who are willing to step forward and admit their responsibility."

In preparing for the sentencing hearing, defense counsel spoke with Washington about his background, but did not seek out character witnesses or request a psychiatric examination. Counsel's decision not to present evidence concerning Washington's character and emotional state reflected his judgment that it was advisable to rely on the plea colloquy for evidence as to such matters, thus preventing the State from cross-examining Washington and from presenting psychiatric evidence of its own. Counsel did not request a presentence report because it would have included Washington's criminal history and thereby would have undermined the claim of no significant prior criminal record.

Finding numerous aggravating circumstances and no mitigating circumstance, the trial judge sentenced Washington to death on each of the murder counts. The Florida Supreme Court affirmed Washington's sentences on direct appeal.

Washington then sought collateral relief in state court on the ground, inter alia, that counsel had rendered ineffective assistance at the sentencing proceeding in several respects, including his failure to request a psychiatric report, to investigate and present character witnesses, and to seek a presentence report. The trial court denied relief, and the Florida Supreme Court affirmed.

Washington then filed a habeas corpus petition in Federal District Court advancing numerous grounds for relief, including the claim of ineffective assistance of counsel. After an evidentiary hearing, the District Court denied relief, concluding that although counsel made errors in judgment in failing to investigate mitigating evidence further than he did, no prejudice to Washington's sentence resulted from any such error in judgment.

The United States Court of Appeals for the Eleventh Circuit reversed the District Court's ruling, stating that the Sixth Amendment accorded criminal defendants a right to counsel rendering "reasonably effective assistance given the totality of the circumstances." After outlining standards for judging whether a defense counsel fulfilled the duty to investigate nonstatutory mitigating circumstances and whether counsel's errors were sufficiently prejudicial to justify reversal, the Eleventh Circuit Court of Appeals remanded the case for application of the standards. The State of Florida appealed the decision to the United States Supreme Court, which granted certiorari.