Sixth Amendment

Issues

The Supreme Court will consider whether Florida’s death sentencing scheme is constitutional in light of Ring v. Arizona, 536 U.S. 584 (2002). See Brief for Petitioner, Timothy Lee Hurst at 26-27. Convicted murderer Timothy Lee Hurst argues that Florida’s capital sentencing scheme is unconstitutional in light of Ring. See id. at 17-18. Hurst contends that the jury’s advisory verdict does not satisfy the requirements of Ring and violates the Constitution because  the it  minimizes the jury’s sense of responsibility and subverts the jury’s deliberative function by assigning the fact-finding role to the trial court judge. See id. at 26-27, 35-36. Florida argues that its sentencing framework is constitutional because it complies with the requirements of Ring and ensures that a judge’s sole determination will not necessitate a sentence of death for a defendant. See Brief of Respondent, Florida at 58. The Court’s decision will determine the constitutionality of Florida’s death sentencing  scheme,  and may impact the individual cases of prisoners who have been sentenced to death in Florida.

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In 1999, Ahmad Edwards stole a pair of shoes from an Indiana department store and then shot at the store security guard who chased after him, wounding the guard and a passer-by. The State of Indiana charged Edwards with theft, criminal recklessness, battery, and attempted murder. In 2004, an Indiana trial court declared Edwards competent to stand trial but later denied Edwards' request to serve as his own lawyer. The judge said that Edwards, a diagnosed schizophrenic, was not competent to represent himself. Edwards then went to trial with counsel, a jury found him guilty, and he was sentenced to thirty years in prison. Edwards appealed, arguing that the court deprived him of his Sixth Amendment right to represent himself at trial. The Indiana Court of Appeals agreed with Edwards and called for a new trial. The appeals court held that once the trial court had found Edwards competent to stand trial, under United States Supreme Court precedent, the court could not impose a higher competency standard to determine whether he could act as his own lawyer. The Indiana Supreme Court affirmed the appeals court's decision. The Supreme Court will consider whether states may impose greater competency standards on defendants who wish to represent themselves than on ordinary defendants.

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Carlos Jimenez was convicted of burglary and, due to a prior felony, received an enhanced sentence of forty-three years in prison. Jimenez appealed to the Texas Third Court of Appeals, but through no fault of his own, was unaware that his appeal was denied until after the statute of limitations expired for him to appeal to the Texas Court of Criminal Appeals. In order to remedy this, the Texas Court of Criminal Appeals granted Jimenez a reinstated appeal, which essentially tolled the statute of limitations for purposes of direct review in state court. After exhausting all state remedies, the United States Court of Appeals for the Fifth Circuit denied Jimenez’s federal petition for habeas corpus, stating that for purposes of the Antiterrorism and Effective Death Penalty Act, 28 U.S.C. 2244(d)(1)(A), “direct review” ended when he initially failed to timely appeal the decision of the Third Court of Appeals, not when his reinstated appeal was exhausted. The United States Supreme Court will decide whether the reinstated appeal tolled the statute of limitations until the completion of the reinstated direct review for purposes of 28 U.S.C. 2244(d)(1)(A).

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Tara Williams was on trial in California state court for special circumstances murder and firearm enhancement. During the trial, over Williams’s objections, the court dismissed a juror on the grounds that he was biased against the prosecution. After an alternate replaced the dismissed juror, the jury convicted Williams on both counts. Williams appealed, claiming that the juror’s dismissal had violated California state law as well as her Sixth Amendment rights. The California Court of Appeals affirmed Williams’ conviction, but only did so by addressing her state law claims, ultimately failing to explicitly discuss the Sixth Amendment issues raised. Williams then filed a writ of habeas corpus pursuant to 28 U.S.C. § 2254 alleging a violation of her Sixth Amendment rights. Though the federal district court denied her petition, the United States Court of Appeals for the Ninth Circuit reversed, finding that Williams’ Sixth Amendment claim had not yet been “adjudicated on the merits” within the meaning of 28 U.S.C. § 2254(d). Warden Deborah K. Johnson appealed, claiming that the California Court of Appeals’ prior ruling was an adjudication on the merits and therefore precluded the subsequent habeas petition.  How the Supreme Court decides the case will determine the degree of deference a federal court hearing a petition for habeas corpus will give a state court decision that does not explicitly address the federal grounds for relief.

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Kerri and Brian Kaley were indicted by a federal grand jury in 2007 for stealing prescription medical devices and selling them on the black market. Along with the indictment, the United States obtained an order to restrain assets traceable to the alleged crime. Because those assets were needed to retain the Kaleys’ counsel of choice, the Kaleys contested the order as violative of their Fifth Amendment right to due process and of their Sixth Amendment right to counsel of choice. Those rights, the Kaleys argued, entitled them to a full pretrial, adversarial hearing at which to challenge the validity of the forfeiture. The Eleventh Circuit Court of Appeals ruled that the Kaleys are entitled only to a hearing at which to challenge the assets’ traceability to the crime—not the underlying charges as well. The Supreme Court’s ruling in this case will impact not only the scope of pretrial asset restraint hearings, but also the ease with which the government may seize assets, as well as defendants’ ability to retain counsel of their choice.

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Around January 2004, Donnie Ray Ventris was arrested and charged with the murder, burglary, and robbery of Ernest Hicks. At his trial, the prosecution offered the testimony of Ventris's cellmate, whom the prosecution had recruited to uncover incriminating information from Ventris. This testimony was obtained in violation of Ventris's Sixth Amendment right to counsel because his counsel had not been present at the time, nor had he waived his right to counsel beforehand. The trial court therefore did not allow the prosecution to use the testimony in its case-in-chief. It did, however, let the prosecution use the testimony for impeachment purposes. Eventually, Ventris was acquitted of felony murder but convicted of robbery and burglary. The Kansas Court of Appeals affirmed. The Kansas Supreme Court, however, reversed because it held that Ventris's statements to his cellmate should not have been admitted for any purpose, including impeachment. The U.S. Supreme Court will now decide whether voluntary statements obtained in the absence of a waiver of one's Sixth Amendment right to counsel can be used for impeachment purposes. The Court's decision will impact the procedural fairness and truth-finding function of criminal trials.

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In 2003, Respondent Anthony Cooper faced trial for assault with intent to murder. Prosecutors offered Cooper two plea deals carrying lesser sentences than he would have received under the sentencing guidelines. Pursuant to the advice of his trial counsel, Cooper rejected both offers and received a sentence demonstrably longer than either plea offer. Cooper claims that the Sixth Amendment guarantees effective assistance of counsel at all critical stages of a criminal proceeding, including the plea bargaining process. Cooper argues that his trial counsel’s ineffective assistance prejudiced his  trial,  and that he is entitled to reinstatement of the plea offer. Petitioner Blaine Lafler argues that rejection of a plea bargain is not a critical stage. Lafler contends that Cooper is not entitled to relief because Cooper received a fair trial and no Sixth Amendment violation occurred. This case will determine the availability of habeas relief to a defendant who may have received constitutionally defective advice from counsel during plea bargaining negotiations.

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Petitioner Jae Lee pleaded guilty to possession of ecstasy with the intent to distribute, an aggravated felony and deportable offense. Lee argues that he is entitled to Strickland relief because ineffective assistance of counsel prejudiced his case. The United States argues that, although Lee did experience ineffective assistance of counsel, he is not entitled to Strickland relief because it would have been unreasonable to seek trial in lieu of a guilty plea in this case. This case allows the Supreme Court to examine what Sixth Amendment constitutional relief is available to noncitizen United States residents that experience ineffective assistance of counsel resulting in mandatory deportation.

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The Supreme Court’s decision in this case will determine whether the United States Government can constitutionally obtain a preliminary injunction under 18 U.S.C. § 1345 (“§ 1345”) to prohibit a defendant facing federal fraud charges from spending assets not derived directly from the charged crime. See Brief for Petitioner, Sila Luis at i. Luis argues that such a preliminary injunction violates a defendant’s right to counsel under the Sixth Amendment, and that the language of § 1345 does not allow the Government to restrain spending of untainted assets. See id. at 17–18, 34–35. Luis also asserts that even if a preliminary injunction of untainted assets is constitutional, the district court violated Fifth Amendment Due Process by failing to determine whether the Government was entitled, beyond a reasonable doubt, to the untainted assets. See id. at 44. On the other hand, the United States argues that the Supreme Court has previously held the Government’s restraint of all assets in a defendant’s possession to be constitutional, so long as the Government can show probable cause that the assets are forfeitable even if the defendant needs those assets to pay for counsel. See Brief for Respondent, United States at 25–26. The Court’s decision could significantly impact criminal defendants’ ability to hire private counsel in cases of federal fraud and will also shape U.S. asset forfeiture law. See Brief of Amicus Curiae American Bar Association, in Support of Petitioner at 7; see also Brief of Amici Curiae National Association of Criminal Defense Lawyers et al., in Support of Petitioner at 5–6.

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