January 20, 2010

Supreme Court Decides Wood v. Allen

On January 20, the Supreme Court decided Wood v. Allen, No. 09-5270, holding that the U.S. Court of Appeals for the Eleventh Circuit correctly denied the application of a convicted murderer for a writ of habeas corpus on grounds of inadequate assistance of counsel.

The Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) limits federal-court review of state-court factual findings in the context of habeas corpus petitions. First, a federal court may not grant a state prisoner's application for a writ based on a claim that has already been adjudicated in state court unless the state court's decision "was based on an unreasonable determination of the facts in light of the evidence presented" in the state proceeding. Second, the state court's factual determination is presumed to be correct, and the petitioner must rebut that presumption by clear and convincing evidence. 28 U.S.C. § 2254 (d)(2) and (e)(1).

Wood was convicted of murder in Alabama state court and sentenced to death. In his application for post-conviction relief from the state court, he argued that his trial lawyers were ineffective because they failed to investigate and present evidence of his alleged mental retardation during the penalty phase of his trial. The state court held a hearing on this contention and denied relief, finding that the lawyers had investigated Wood's mental condition and had made a strategic decision not to present evidence about it. The court also found that there was no reasonable probability of a different outcome if the evidence had been presented at trial.

When Wood sought habeas relief in federal court, the district court concluded that the state court's finding that trial counsel had made a strategic decision was an unreasonable determination on the facts, that counsel's performance was deficient, and that it had prejudiced Wood. The Court of Appeals for the Eleventh Circuit reversed, holding that the state court's rejection of Wood's ineffective-assistance claim was not based on an unreasonable determination of the facts and that relief therefore was barred by § 2254(d)(2) of AEDPA.

The Supreme Court affirmed the court of appeals' decision. It declined to decide whether § 2254(e)(1)'s presumption in favor of state-court factual findings and requiring their rebuttal by "clear and convincing evidence" applies in every case challenging such findings, because it found that, even if the presumption and the related burden of rebuttal did not apply here, the state court's finding that the trial lawyers had made a strategic decision not to present evidence about Wood's mental condition, rather than negligently ignoring the matter, was not "unreasonable" as required by § 2254(d)(2).

The Court observed that a state-court finding is not unreasonable simply because the federal habeas court would have reached a different conclusion in the first instance, and it noted that the state court's finding was supported by evidence showing that Wood's trial lawyers had obtained a medical evaluation of Wood's mental condition, reviewed it, and affirmatively decided not to present testimony about it in the penalty phase of the trial. The Court emphasized the difference between the reasonableness of the state court's finding that the lawyers had made a strategic decision and the reasonableness of the lawyers' decision, construing Wood's petition for certiorari as not having raised the latter question.

Justice Sotomayor delivered the opinion of the Court, in which Chief Justice Roberts and Justices Scalia, Thomas, Ginsburg, Breyer, and Alito joined. Justice Stevens filed a dissenting opinion, in which Justice Kennedy joined.

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