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Abstract
| Argument: |
Monday, October 4, 1999
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| Decision: |
Tuesday, April 18, 2000 |
| Issues: |
Criminal Procedure, Habeas Corpus |
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Advocates
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Facts of the Case
After Terry Williams was convicted of robbery and capital murder; his punishment was fixed at death. In state habeas corpus proceedings a judge determined that his conviction was valid. However, the judge also found that Williams' counsel's failure to discover and present significant mitigating evidence violated his right to effective counsel and recommended that he be re-sentenced. Rejecting this, the Virginia Supreme Court held that Williams had not suffered sufficient prejudice to warrant relief. In habeas corpus proceedings under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), a federal trial judge also found that the death sentence was constitutionally weak on ineffective-assistance grounds. The court, under the AEDPA, concluded that the Virginia Supreme Court's decision "was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States." In reversing, the Court of Appeals determined that it could not conclude that the Virginia Supreme Court's decision on prejudice was an unreasonable application of standards established by the Supreme Court.
Question
Was Terry Williams' constitutional right to the effective assistance of counsel violated? Was the judgment of the Virginia Supreme Court refusing to set aside Williams' death sentence "contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States?"
Conclusion
Yes and yes. In a judgment announced by Justice John Paul Stevens, the Court, with different majorities of Justices for each holding, held that Williams had been deprived of the constitutional right to the effective assistance of counsel and that the Virginia Supreme Court's refusal to set aside the Williams death sentence was a decision that was contrary to or involved an unreasonable application of clearly established federal law, as determined by the Court. This conclusion followed from "'a reasonable probability that the result of the sentencing proceeding would have been different' if competent counsel had presented and explained the significance of all the available evidence.'"