Term: 2006
Docket: 05-1575
Dora B. Schriro, Director, Arizona Department Of Corrections v. Jeffrey Timothy Landrigan, Aka Billy Patrick Wayne Hill
- Pro
05-1575 SCHRIRO V. LANDRIGAN DECISION BELOW:441 F3d 638 CERT. GRANTED 9/26/2006 QUESTIONS PRESENTED: Respondent Jeffrey Landrigan actively thwarted his attorney’s efforts to develop and present mitigation evidence in his capital sentencing proceeding. Landrigan told the trial judge that he did not want his attorney to present any mitigation evidence, including proposed testimony from witnesses whom his attorney had subpoenaed to testify. On post-conviction review, the state court rejected as frivolous an ineffective assistance of counsel claim in which Landrigan asserted that if counsel had raised the issue of Landrigan’s alleged genetic predisposition to violence, he would have cooperated in presenting that type of mitigating evidence. 1. In light of the highly deferential standard of review required in this case pursuant to the Anti-Terrorism and Effective Death Penalty Act of 1996 (“AEDPA”), did the Ninth Circuit err by holding that the state court unreasonably determined the facts when it found that Landrigan “instructed his attorney not to present any mitigating evidence at the sentencing hearing”? 2. Did the Ninth Circuit err by finding that the state court’s analysis of Landrigan’s ineffective assistance of counsel claim was objectively unreasonable under Strickland v. Washington, 466 U.S. 668 (1984), notwithstanding the absence of any contrary authority from this Court in cases in which (a) the defendant waives presentation of mitigation and impedes counsels attempts to do so, or (b) the evidence the defendant subsequently claims should have been presented is not mitigating? LOWER COURT CASE NUMBER: 00-99011
In the case of Dora B. Schriro, Director, Arizona Department of Corrections v. Jeffrey Timothy Landrigan (aka Billy Patrick Wayne Hill), 2006, the U.S Supreme Court considered whether a defendant's refusal to allow his attorney to present mitigating evidence during sentencing in a capital murder trial constituted ineffective assistance of counsel. The court also examined if such refusal could be grounds for habeas corpus relief under federal law when state courts had found it procedurally defaulted. Landrigan was convicted and sentenced to death for murder in Arizona but argued that his lawyer failed him by not presenting mitigating evidence about his troubled background during sentencing phase which might have led to a lesser sentence than death penalty. However, he himself had instructed his lawyer not to present any such evidence at trial and even interrupted proceedings insisting on this point. The Supreme Court ruled against Landrigan stating that given the overwhelming aggravating factors compared with minimal potential mitigating circumstances presented by defense counsel’s failure did not undermine confidence in the outcome i.e., there was no "reasonable probability" that result would have been different if additional mitigation evidence were presented as required for proving ineffective assistance claim.
In the case of Schriro v. Landrigan, Justice Stevens dissented from the majority opinion. He argued that Jeffrey Timothy Landrigan's counsel was ineffective for not presenting mitigating evidence during his sentencing hearing and that this failure could have affected the outcome of his sentence. The dissenting opinion emphasized that a defendant has a constitutional right to effective legal representation, which includes having all relevant mitigating evidence presented at their trial. Justice Stevens believed that since this did not occur in Landrigan's case, he should be granted an evidentiary hearing to determine whether or not it would have made a difference in his death penalty sentence.
