Term: 2002
Docket: 02-311
Kevin Wiggins v. Sewall Smith, Warden, Et Al.
- Pro
02-311 WIGGINS v. CORCORAN Ruling below: CA 4, 288 F.3d 629. QUESTIONS PRESENTED In this case, the United States Court of Appeals for the Fourth Circuit held that under 28 U.S.C. § 2254(d)(I), a state court application of established federal law will satisfy the "objectively reasonable" standard of review set forth in Williams v. Taylor, 529 U.S. 362 (2000), so long as it is "minimally consistent with the facts and circumstances of the case." The questions presented are: 1. Does the Due Process standard of Jackson v. Virginia require a court to consider "all of the evidence" in deciding whether a reasonable factfinder could have found guilt beyond a reasonable doubt, as this Court held in Jackson and the First, Fifth and Seventh Circuits have likewise held, or may a conviction based entirely on circumstantial evidence be upheld under Jackson by considering only the evidence consistent with guilt and ignoring all evidence refuting guilt, as the Fourth Circuit held in this case. 2. Does defense counsel in a capital case violate the requirements of Strickland v. Washington by failing to investigate available mitigation evidence that could well have convinced a jury to impose a life sentence, as this Court concluded in Williams v. Taylor and as most Courts of Appeals have concluded, or is defense counsel's decision not to investigate such evidence "virtually unchallengeable" so long as counsel knows rudimentary facts about the defendant's background, as the Fourth Circuit held in this case. CERT. GRANTED: 11/18/02 Limited to question 2 presented by the petition.
In the 2002 case of Kevin Wiggins v. Sewall Smith, Warden et al., the U.S Supreme Court ruled in favor of Wiggins, a death row inmate who argued that his legal representation during sentencing was ineffective due to their failure to investigate and present mitigating evidence about his background. The court found that if this information had been presented at trial - including severe childhood abuse and neglect, borderline mental retardation, and chronic substance abuse - there is reasonable probability that it would have influenced the jury's decision towards life imprisonment rather than capital punishment. Therefore, by not investigating or presenting this evidence during sentencing phase of trial, Wiggin’s defense counsel provided constitutionally deficient representation which violated his Sixth Amendment right to effective assistance of counsel.
In the dissenting opinion for the case of Kevin Wiggins v. Sewall Smith, Justice Scalia disagreed with the majority's ruling that ineffective counsel had been provided during sentencing. He argued that there was no definitive proof to suggest that a different approach by Wiggins' lawyers would have resulted in a lighter sentence. Furthermore, he contended that it was not clear whether or not presenting evidence of Wiggins' troubled past would have swayed jurors towards leniency or further convinced them of his guilt due to his history of violence and criminal behavior. In essence, Scalia believed there were too many uncertainties and hypotheticals involved in this decision-making process to definitively state that ineffective assistance had occurred.
