Wiggins v. Smith
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''Wiggins v. Smith'', 539 U.S. 510 (2003), is a case in which the
United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
spelled out standards for "
effectiveness Effectiveness is the capability of producing a desired result or the ability to produce desired output. When something is deemed effective, it means it has an intended or expected outcome, or produces a deep, vivid impression. Etymology The ori ...
" in the
constitutional right A constitutional right can be a prerogative or a duty, a power or a restraint of power, recognized and established by a sovereign state or union of states. Constitutional rights may be expressly stipulated in a national constitution, or they may ...
to
legal counsel A lawyer is a person who practices law. The role of a lawyer varies greatly across different legal jurisdictions. A lawyer can be classified as an advocate, attorney, barrister, canon lawyer, civil law notary, counsel, counselor, solicitor, ...
guaranteed by the Sixth Amendment.. Previously the court had determined that the Sixth Amendment included the right to "effective assistance" of legal counsel, but it did not specify what constitutes "effective", thus leaving the standards for effectiveness vague. In ''Wiggins v. Smith'', the court set forth the
American Bar Association The American Bar Association (ABA) is a voluntary bar association of lawyers and law students, which is not specific to any jurisdiction in the United States. Founded in 1878, the ABA's most important stated activities are the setting of acad ...
Guidelines for the Appointment and Performance of Defense Counsel in Death Penalty Cases Guideline 11.8.6.(1989), as a specific guideline by which to measure effectiveness and competence of legal counsel. In ''
Strickland v. Washington ''Strickland v. Washington'', 466 U.S. 668 (1984), was a landmark Supreme Court case that established the standard for determining when a criminal defendant's Sixth Amendment right to counsel is violated by that counsel's inadequate performance ...
'', the Supreme Court set forth the factors the defendant must establish to demonstrate that counsel was ineffective. First, it must be shown that counsel's performance fell below an objective standard of reasonable competence, and second, if counsel had not been competent, that the trial outcome would likely have been different had the counsel been competent.


Background

On September 17, 1988, a woman was found dead in her bathtub, with signs of
sexual assault Sexual assault is an act in which one intentionally sexually touches another person without that person's consent, or coerces or physically forces a person to engage in a sexual act against their will. It is a form of sexual violence, which ...
and her apartment ransacked. Defendant Wiggins had been painting at her apartment building and was seen conversing with her on September 15. That same evening he went shopping with the victim's
credit card A credit card is a payment card issued to users (cardholders) to enable the cardholder to pay a merchant for goods and services based on the cardholder's accrued debt (i.e., promise to the card issuer to pay them for the amounts plus the o ...
s and took some of her jewelry to a
pawnbroker A pawnbroker is an individual or business (pawnshop or pawn shop) that offers secured loans to people, with items of personal property used as collateral. The items having been ''pawned'' to the broker are themselves called ''pledges'' or ...
. Four days later, Wiggins was arrested while driving the victim's car. Wiggins was found guilty of capital
murder Murder is the unlawful killing of another human without justification (jurisprudence), justification or valid excuse (legal), excuse, especially the unlawful killing of another human with malice aforethought. ("The killing of another person wit ...
after a
bench trial A bench trial is a trial by judge, as opposed to a trial by jury. The term applies most appropriately to any administrative hearing in relation to a summary offense to distinguish the type of trial. Many legal systems (Roman, Islamic) use bench ...
. After the trial, Wiggins elected to have a
jury A jury is a sworn body of people (jurors) convened to hear evidence and render an impartiality, impartial verdict (a Question of fact, finding of fact on a question) officially submitted to them by a court, or to set a sentence (law), penalty o ...
decide the sentence on the murder conviction. Counsel's investigation of Wiggins' background was rudimentary and contained only a superficial knowledge of his history from a few sources, omitting the information in detailed social service reports of severe physical and sexual abuse. The record of the sentencing proceedings suggests that counsels' failure to investigate the defendant's background stemmed from inattention, not strategic judgment. Counsel failed to follow the
American Bar Association The American Bar Association (ABA) is a voluntary bar association of lawyers and law students, which is not specific to any jurisdiction in the United States. Founded in 1878, the ABA's most important stated activities are the setting of acad ...
guidelines in not gathering all such information. Counsel said they had been intent on proving the defendant did not kill the victim with his own hand and had not prepared for the sentencing phase. Counsel presented no
mitigating evidence Mitigating evidence is evidence that is provided (usually by the defendant in a criminal trial) in order to try to establish the presence of mitigating circumstances. The presence of mitigating circumstances can reduce the punishment imposed for ...
to the jury at the sentencing phase. The jury concluded that the defendant was a principal in the
first degree murder Murder is the unlawful killing of another human without justification or valid excuse, especially the unlawful killing of another human with malice aforethought. ("The killing of another person without justification or excuse, especially the c ...
of the victim and sentenced Wiggins to
death Death is the irreversible cessation of all biological functions that sustain an organism. For organisms with a brain, death can also be defined as the irreversible cessation of functioning of the whole brain, including brainstem, and brain ...
. Wiggins obtained new counsel and sought post conviction relief on the grounds that his trial counsel was ineffective by failing to investigate and present mitigating evidence of his dysfunctional background. He presented expert testimony by a forensic mental health specialist who described his personal history including the severe physical and sexual abuse he had endured and its effect upon him. At a hearing, one of Wiggins' trial counsels testified that he had Wiggins' social services records before sentencing, and knew that it could be a mitigating factor in a capital case, but believed that the way to avoid the death penalty was to create reasonable doubt that petitioner was a principal in the first degree rather than present the mitigating factors. The state provided a post-conviction review of his case and the
Maryland Court of Appeals The Supreme Court of Maryland is the state supreme court, highest court of the U.S. state of Maryland. Its name was changed on December 14, 2022, from the Maryland Court of Appeals, after a voter-approved change to the state constitution. The cou ...
upheld the trial court's findings. Wiggins then filed for federal
habeas corpus ''Habeas corpus'' (; from Medieval Latin, ) is a recourse in law through which a person can report an unlawful detention or imprisonment to a court and request that the court order the custodian of the person, usually a prison official, t ...
relief. The
Federal District Court The United States district courts are the trial courts of the U.S. federal judiciary. There is one district court for each federal judicial district, which each cover one U.S. state or, in some cases, a portion of a state. Each district cou ...
found that defense counsel did not provide effective assistance at sentencing. However, on appeal, the
Fourth Circuit Court of Appeals The United States Court of Appeals for the Fourth Circuit (in case citations, 4th Cir.) is a federal court located in Richmond, Virginia, with appellate jurisdiction over the district courts in the following districts: * District of Maryland ...
reversed, finding that defense counsel provided reasonable application of ''
Strickland v. Washington ''Strickland v. Washington'', 466 U.S. 668 (1984), was a landmark Supreme Court case that established the standard for determining when a criminal defendant's Sixth Amendment right to counsel is violated by that counsel's inadequate performance ...
'' (1984) standards. Upon appeal, the Supreme Court granted Wiggins' petition for
certiorari In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of an English prerogative writ, issued by a superior court to direct that the record of ...
.


Decision

The Supreme Court granted a new sentencing hearing, holding that Wiggins' Sixth Amendment right to effective assistance of counsel was violated. Trial counsel failed to adequately investigate and present mitigating evidence such as Wiggins' personal and social history of severe
physical abuse Physical abuse is any intentional act causing injury or trauma to another person or animal by way of bodily contact. In most cases, children are the victims of physical abuse, but adults can also be victims, as in cases of domestic violence or wo ...
and
sexual assault Sexual assault is an act in which one intentionally sexually touches another person without that person's consent, or coerces or physically forces a person to engage in a sexual act against their will. It is a form of sexual violence, which ...
, and none of this information was presented at the penalty phase of trial, thus prejudicing Wiggins' defense. The Supreme Court's decision stated that such an investigation is a key component of the strategic decision regarding what, if any, mitigating evidence to present during a sentencing hearing. The Court further held that the counsel's decision in defending a client facing the death penalty must be based on a thorough investigation of all possible
mitigating factor In criminal law, a mitigating factor, also known as an extenuating circumstance, is any information or evidence presented to the court regarding the defendant or the circumstances of the crime that might result in reduced charges or a lesser sente ...
s. Failing that, it must be based on competent professional judgment providing sound reasons for limiting the investigation.


Significance

The Supreme Court attempted to improve on the vague and generalized language in ''Strickland v. Washington'' by adding an American Bar Association Guideline 11.8.6. This guideline suggests the content of counsel's investigative efforts should contain "medical history, educational history, employment and training history, family and social history, prior adult and juvenile correctional experience, and religious and cultural influences." This clarification allows for the presentation of psychological analysis without the presence of specific diagnosis.


See also

*''
Bigby v. Dretke ''Bigby v. Dretke'' 402 F.3d 551 (5th Cir. 2005), the U.S. Court of Appeals for the Fifth Circuit heard a case appealed from the United States District Court for the Northern District of Texas (trial court) on the issue of the instructions given ...
'' (5th Cir. 2005) *
List of United States Supreme Court cases, volume 539 This is a list of all the United States Supreme Court cases from volume 539 of the ''United States Reports The ''United States Reports'' () are the official record ( law reports) of the Supreme Court of the United States. They include rulings, ...
*
List of United States Supreme Court cases This page serves as an index of lists of United States Supreme Court cases. The United States Supreme Court is the highest federal court of the United States. By Chief Justice Court historians and other legal scholars consider each Chief J ...


References


Further reading

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External links

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{{Sixth Amendment, counsel, state=expanded United States Sixth Amendment ineffective assistance of counsel case law United States Supreme Court cases United States Supreme Court cases of the Rehnquist Court 2003 in United States case law