Term: 2002
Docket: 02-524
Janette Price, Warden v. Duyonn Andre Vincent
- Pro
02-524 JONES v. VINCENT Ruling below: CA 6, 292 F.3d 506. QUESTIONS PRESENTED FOR REVIEW: 1. Whether the Michigan Supreme Court's conclusion that the trial court did not direct a verdict of acquittal is a factual finding entitled to deference on habeas corpus review. 2. Whether Defendant Vincent was twice placed in jeopardy by the action of the trial court in first granting a motion for directed verdict on the issue of first degree murder, and shortly thereafter withdrawing its grant, where both the initial decision and its recall occurred out of the presence of the jury. 3. Whether this Court should grant certiorari to clarify the jurisprudence where there is a split of opinion within the United States Courts of Appeals and within the Sixth Circuit Court of Appeals and State Courts on the question of whether double jeopardy principles were violated in factually similar situations. CERT. GRANTED: 1/10/03
In the case of Janette Price, Warden v. Duyonn Andre Vincent in 2002, the United States Supreme Court addressed a habeas corpus petition from Vincent who was convicted for murder and sentenced to life imprisonment without parole. The main issue revolved around whether or not Vincent's Sixth Amendment right to effective counsel had been violated due to his attorney's failure to object during sentencing when hearsay evidence was used against him. The court ruled that even if there were errors made by his defense lawyer, they did not have a substantial impact on the outcome of his trial and thus did not constitute ineffective assistance of counsel under Strickland v. Washington standards (a precedent which sets forth two-pronged test for determining ineffectiveness: deficient performance by counsel and prejudice as a result). Therefore, it upheld Vincent’s conviction and sentence.
In the dissenting opinion for the case of Janette Price, Warden v. Duyonn Andre Vincent, Justice Scalia disagreed with the majority's decision to grant habeas corpus relief based on ineffective assistance of counsel during sentencing. He argued that there was no constitutional right to a plea bargain and thus no basis for claiming ineffective counsel if such a deal wasn't reached or offered. Furthermore, he contended that even if there were such a right, it would be impossible to determine whether an attorney's performance had been deficient without knowing what might have happened in an alternative scenario where they acted differently - something inherently unknowable and speculative. Therefore, according to him, Vincent failed both prongs of Strickland test: proving his lawyer’s performance was deficient and this deficiency prejudiced his defense.
