JURIST - Paper Chase: Supreme Court rejects ineffective assistance of counsel claim in capital case

[JURIST] The US Supreme Court [official website; JURIST news archive] on Wednesday ruled [opinion, PDF] 7-2 in Wood v. Allen [Cornell LII backgrounder; JURIST report] that a state court reasonably concluded that, during the sentencing phase of a capital case, the defense attorney's failure to present the defendant's impaired mental functioning did not constitute ineffective counsel. The Court affirmed the decision [opinion, PDF] of the US Court of Appeals for the Eleventh Circuit, finding it had correctly applied the Antiterrorism and Effective Death Penalty Act (AEDPA) [text, PDF] to the review the state court decision. Writing for the majority, Justice Sonia Sotomayor concluded:

We hold simply that, even under petitioner's reading of § 2254(d)(2) [of the AEDPA], the state court's conclusion that Wood's counsel made a strategic decision not to pursue or present evidence of his mental deficiencies was not an unreasonable determination of the facts.

The Court did not reach the question of how AEDPA § 2254(e)(1), which provides that the petitioner has the burden of challenging a state court's findings of facts by clear and convincing evidence, applies in challenges to a state court's factual determinations under § 2254(d)(2). Justice John Paul Stevens filed a dissenting opinion, joined by Justice Anthony Kennedy.

The defendant, Holly Wood, broke into his ex-girlfriend's home in 1993, shooting and killing her. Wood was convicted on capital murder charges and sentenced to death. After his conviction and sentence were affirmed by the Alabama Court of Criminal Appeals and the Alabama Supreme Court, Wood petitioned for federal habeas relief. Wood argued that his counsel's failure to investigate and present mitigation evidence of his mental deficiencies during the penalty phase constituted ineffective assistance of counsel. The district court granted habeas relief, but the Eleventh Circuit reversed.