Term: 2008
Docket: 07-1315
Michael A. Knowles, Warden v. Alexandre Mirzayance
- Pro
07-1315 KNOWLES V. MIRZAYANCE DECISION BELOW: Petition Appendix B CERT. GRANTED 6/27/2008 QUESTION PRESENTED: Concluding that defense counsel was ineffective in advising petitioner to withdraw his not-guilty-by-reason-of-insanity plea, the Ninth Circuit Court of Appeals granted habeas relief to petitioner without analyzing the state-court adjudication deferentially under “clearly established” law as required by 28 U.S.C. § 2254(d) and by supplanting the district court’s factual findings and credibility determinations with its own, opposite factual findings. This Court vacated the Ninth Circuit decision and remanded the case for further consideration in light of Carey v. Musladin, 127 S. Ct. 649 (2006). On remand, the Ninth Circuit conceded that “no Supreme Court case has specifically addressed a counsel’s failure to advance the defendant’s only affirmative defense” but nonetheless concluded that its original decision was “unaffected” by Musladin and subsequent § 2254(d) decisions of this Court. The questions presented are: 1. Did the Ninth Circuit again exceed its authority under § 2254(d) by granting habeas relief without considering whether the state-court adjudication of the claim was “unreasonable” under “clearly established Federal law” based on its previous conclusion that trial counsel was required to proceed with an affirmative insanity defense because it was the only defense available and despite the absence of a Supreme Court decision addressing the point? 2. May a federal appellate court substitute its own factual findings and credibility determinations for those of a district court without determining whether the district court’s findings were “clearly erroneous?” LOWER COURT CASE NUMBER: 04-57102
In the case of Michael A. Knowles, Warden v. Alexandre Mirzayance, the U.S. Supreme Court ruled in favor of Knowles, reversing a decision by the Ninth Circuit Court of Appeals that had granted habeas corpus relief to Mirzayance on his claim of ineffective assistance of counsel during his murder trial and subsequent penalty phase retrial. The court held that an attorney's advice to withdraw an insanity defense did not constitute ineffective assistance because it was based on reasonable professional judgment given the circumstances at hand - including weak evidence supporting this defense and potential negative impact on jury sympathy towards defendant in sentencing phase if they rejected this plea initially. The court further noted that even though this strategy ultimately failed (resulting in a death sentence), failure does not equate ineffectiveness under legal standards for assessing counsel performance.
In the dissenting opinion for the case of Michael A. Knowles, Warden v. Alexandre Mirzayance, Justice Clarence Thomas disagreed with the majority's decision that Mirzayance’s counsel was ineffective during his trial and sentencing phases. He argued that there was no precedent to support this claim and believed it was reasonable for a defense attorney to withdraw an insanity plea if they thought it would be unsuccessful in court. Furthermore, he contended that even if such a strategy failed, it did not necessarily mean that counsel's performance fell below an objective standard of reasonableness as required by Strickland v. Washington (1984). In essence, Justice Thomas felt the majority had overstepped its bounds by second-guessing strategic decisions made by defense attorneys based on their professional judgment.
