Wood v. Allen
Court will review inadequate counsel claim in death row case (May 18, 2009)
The Supreme Court has agreed to examine two questions in the case of an Alabama death row inmate.
The court first question will address the failure of an inexperienced defense attorney to present in a capital sentencing proceeding evidence of the defendant's severe mental impairment.
The second question examines how federal courts should review state court factual findings under the Antiterrorism and Effective Death Penalty Act (AEDPA), which drastically altered the role of federal courts in ruling on federal habeas corpus petitions from state prisoners.
In 1994, an Alabama state court convicted Holly Wood of capital murder for the death of his former girlfriend, Ruby Lois Gosha, in 1993. He was sentenced to death.
Both the Alabama Court of Criminal Appeals and the Alabama Supreme Court affirmed the conviction and sentence. Wood subsequently filed for post-conviction relief under Alabama Rule of Criminal Procedure 32, arguing that he was mentally retarded and thus not eligible for a death sentence and that his trial counsel was ineffective.
His petition was denied and in May 2004, he then filed for federal habeas corpus relief in an Alabama federal district court. In November 2006, the district court granted relief, agreeing that Wood's counsel was ineffective at sentencing.
Last September, a divided three-judge panel of the 11th U.S. Circuit Court of Appeal reversed, holding that Wood's counsel was not ineffective.
The court reasoned that Wood's attorneys acted reasonably when they decided it was in Wood's best interest to leave out information that illustrated his mental deficiencies. Moreover, the court recognized that while Wood's counsel included an inexperienced attorney, he merely acted as an assistant to the two experienced attorneys chiefly responsible for the case.
Question presented: Whether the state court’s conclusion–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–was based on an unreasonable determination of the facts and whether the circuit court erred in its application of the Antiterrorism and Effective Death Penalty Act (AEDPA) to the review of the state court decision.
Court rules on inadequate counsel claim in death row case (Jan. 20, 2010)
The Supreme Court let stand the death sentence of a mentally impaired Alabama inmate convicted of killing his former girlfriend.
The court first question in the case addressd the failure of an inexperienced defense attorney to present in a capital sentencing proceeding evidence of the defendant's severe mental impairment.
The second question examined how federal courts should review state court factual findings under the Antiterrorism and Effective Death Penalty Act (AEDPA), which drastically altered the role of federal courts in ruling on federal habeas corpus petitions from state prisoners.
In 1994, an Alabama state court convicted Holly Wood of capital murder for the death of his former girlfriend, Ruby Lois Gosha, in 1993. He was sentenced to death.
Both the Alabama Court of Criminal Appeals and the Alabama Supreme Court affirmed the conviction and sentence. Wood subsequently filed for post-conviction relief under Alabama Rule of Criminal Procedure 32, arguing that he was mentally retarded and thus not eligible for a death sentence and that his trial counsel was ineffective.
His petition was denied and in May 2004, he then filed for federal habeas corpus relief in an Alabama federal district court. In November 2006, the district court granted relief, agreeing that Wood's counsel was ineffective at sentencing.
Last September, a divided three-judge panel of the 11th U.S. Circuit Court of Appeal reversed, holding that Wood's counsel was not ineffective.
The court reasoned that Wood's attorneys acted reasonably when they decided it was in Wood's best interest to leave out information that illustrated his mental deficiencies. Moreover, the court recognized that while Wood's counsel included an inexperienced attorney, he merely acted as an assistant to the two experienced attorneys chiefly responsible for the case.
On Jan. 20, the Supreme Court affirmed the lower court order in a 7-2 decision written by Justice Sonia Sotomayor.
"Even if it is debatable, it is not unreasonable to conclude that ... counsel made a strategic decision not inquire further into the information contained in the report about Wood's mental deficiencies and not present to the jury such information," Sotomayor wrote.
Justice John Paul Stevens, joined by Justice Anthony Kennedy dissented. Stevens noted that he did not understand why Wood's attorney decided not investigate or present "powerful mitigating evidence of Wood's mental deficits for the penalty phase" of the trial.
"The only reasonable factual conclusion I can draw from this record is that counsel's decision to do so was the result of inattention and neglect," he wrote.
Question presented: Whether the state court’s conclusion–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–was based on an unreasonable determination of the facts and whether the circuit court erred in its application of the Antiterrorism and Effective Death Penalty Act (AEDPA) to the review of the state court decision.