Schriro v. Landrigan
Issues
Whether a state appellate court's interpretation of trial court proceedings is a finding of fact that is entitled to deference under the AEDPA.
Whether the Supreme Court's ruling in Strickland v. Washington allows a state court to deny an ineffective assistance of counsel claim when the defendant originally waives the presentation of assumedly mitigating evidence, but later claims that the evidence was erroneously excluded, especially when the state court determines that the exclusion of mitigation did not prejudice the sentence.
What must a defense attorney do when faced with a client who, after being found guilty of murder, refuses to allow family members to testify prior to his sentencing, even though those family members would introduce evidence that might result in the reduction of his sentence? In this case, the Supreme Court will address the extent to which a criminal defendant may claim that his defense attorney acted incompetently by not introducing mitigating evidence during his trial, even when the defense attorney directly follows his orders not to do so. Furthermore, the Court will determine the extent to which a federal court may review and overturn a defendant's state court sentence if he claims his attorney acted incompetently.
Questions as Framed for the Court by the Parties
1. In light of the highly deferential standard of review required in this case pursuant to the Anti-Terrorism and Effective Death Penalty Act of 1996 (“AEDPA”), did the
Ninth Circuit err by holding that the Arizona state court unreasonably determined the facts when it found that Landrigan “instructed his attorney not to present any mitigating evidence at the sentencing hearing”?
2. Did the Ninth Circuit err by finding that the Arizona state court's analysis of Landrigan's ineffective assistance of counsel claim was objectively unreasonable under
Strickland v. Washington, 466 U.S. 668 (1984), notwithstanding the absence of any contrary authority from this Court in cases in which (a) the defendant waives presentation of mitigation and impedes counsel's attempts to do so, or (b) the evidence the defendant subsequently claims should have been presented is not mitigating?
An Arizona state court convicted Respondent Jeffrey Landrigan of first-degree murder in 1990. See Petition for Certiorari at 1,2. After Landrigan's conviction, the trial court considered evidence of aggravating and mitigating circumstances. See id at 2.