Rompilla v. Beard

545 U.S. 374 (2005)

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Nature of the Case

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Facts

James Scanlon was discovered dead in a bar he owned. His body had been stabbed repeatedly and set on fire. D was indicted for the murder and related offenses, and the Commonwealth gave notice of intent to ask for the death penalty. Two public defenders were assigned to the case. D was found guilty on all counts. During the penalty phase, the prosecutor sought to prove three aggravating factors to justify a death sentence: that the murder was committed in the course of another felony; that the murder was committed by torture; and that D had a significant history of felony convictions indicating the use or threat of violence. P presented evidence on all three aggravators, and the jury found all proven. D's evidence in mitigation was for five of his family members to plead for mercy and that they believed D was innocent and a good man. D's 14-year-old son testified that he loved his father and would visit him in prison. The jury acknowledged this evidence and found two factors in mitigation; that D's son had testified on his behalf and that rehabilitation was possible. They assigned greater weight to the aggravating factors, and sentenced D to death. The Supreme Court of Pennsylvania affirmed both conviction and sentence. With new lawyers, D filed claims for post-conviction relief. D claimed ineffective assistance by trial counsel in failing to present significant mitigating evidence about D's childhood, mental capacity and health, and alcoholism. The post-conviction court found that trial counsel had done enough to investigate the possibilities of a mitigation case, and the Supreme Court of Pennsylvania affirmed the denial of relief. D petitioned for a writ of habeas corpus under 28 U. S. C. §2254. The District Court found that the State Supreme Court had unreasonably applied Strickland as to the penalty phase of the trial, and granted relief for ineffective assistance of counsel. The court found that in preparing the mitigation case, the defense lawyers had failed to investigate 'pretty obvious signs' that D had a troubled childhood and suffered from mental illness and alcoholism, and instead had relied unjustifiably on D's own description of an unexceptional background. The Third Circuit reversed. The investigation for D was far enough to leave counsel with reason for thinking further efforts would not be a wise use of the limited resources they had. Dissent stressed the lawyers' unreasonable reliance on family members and medical experts to tell them what records might be useful. The Supreme Court granted certiorari.