Ineffective Assistance in Plea Bargaining?

Tag Archives: ineffective assistance of counsel

Ineffective Assistance in Plea Bargaining?

Posted on November 2, 2011 by Jeff Welty

On Halloween, I was dressed up as a sheep, trick or treating with my daughter, Little Bo Peep. Fortunately, serious legal business was being conducted elsewhere: the Supreme Court heard oral argument in Lafler v. Cooper, a fascinating ineffective assistance of counsel case. Here’s a summary of the case, courtesy of SCOTUSblog:

Cooper shot a woman, striking her several times below the waist. He was arrested and charged with assault with intent to murder, possession of a firearm by a felon, and other charges. The state offered a plea bargain under which Cooper could plead guilty to the assault with intent to murder charge and face a minimum sentence of fifty-one to eighty-five months in prison. Although Cooper was inclined to take the plea, his counsel advised him that, because the victim was injured below the waist, the state could not establish an element of its case, i.e., intent to murder. Based on this erroneous advice, Cooper rejected the deal. Cooper was later convicted at trial and received a sentence of between 185 and 360 months in prison.

The defendant eventually sought, and obtained, federal habeas relief based on ineffective assistance of counsel. Applying the well-settled two-pronged Strickland test for ineffective assistance of counsel, he argued (1) that his attorney performed deficiently by giving him legally inaccurate advice, which (2) resulted in prejudice when he rejected the plea offer, and ultimately received a sentence three times as long as he would have received under the deal. At least by the time the case reached the Supreme Court, the state conceded that defense counsel’s advice was wrong and that the lawyer performed deficiently, but argued that the defendant had suffered no prejudice, because he had received a fair trial and had relinquished no rights based on the faulty advice.

Over at Crime and Consequences, a prosecution-oriented blog, the thinking is this: a fair trial is the benchmark way of adjudicating criminal cases. A defendant who receives such a trial can’t complain about the result. Perhaps he didn’t get a windfall — a reduced sentence obtained through plea bargaining — but there is no right to such a windfall. (For more detail, look at the posts here and here.) This point of view can be summed up in a question asked by Justice Kennedy during oral argument: “You are saying it was unfair to have a fair trial?”

The defense counters that most cases are resolved by plea bargaining, making plea bargaining a critical stage of any criminal case, a point recently acknowledged by the court in Padilla v. Kentucky. On this view, prejudice is measured not just by whether the defendant relinquished rights based on counsel’s deficient performance, but by whether the defendant received a longer sentence than he otherwise would have received. The defense contends that “the approach advocated by the state [in Lafler] has been rejected by twelve federal courts of appeals and twenty-five of the twenty-seven states in which the issue has arisen.” (I couldn’t quickly find a case directly on point in North Carolina, but in State v. Simmons, 65 N.C.App. 294 (1983), the court of appeals awarded a new trial to a defendant whose lawyer failed to communicate a plea offer to him, perhaps implicitly rejecting the idea that a defendant who receives a fair trial can never show that he was harmed by poor lawyering during plea negotiations. If you know of a case more closely on point, please let me know.)

Lafler is an interesting case. Even if the defendant prevails, there’s a question about the proper remedy. Is the defendant entitled to specific performance of the plea bargain? Is he entitled to choose whether to accept the plea offer, and to turn it down in favor of a new trial if, for example, key witnesses have died or moved? Or should his conviction simply be set aside, with the parties free to negotiate anew or to proceed to trial as they please?

The New York Times covers the case here. The oral argument transcript is available here. I should add that the case was heard along with a companion case, Missouri v. Frye, raising similar issues on what appear to be less compelling facts.

Category: Procedure, Uncategorized | Tags: cooper, effective assistance of counsel, ineffective assistance of counsel, lafler, plea bargaining

Is Padilla Retroactive?

Posted on October 4, 2011 by Jessica Smith

In a post here [editor’s note: the post shows up with my picture for technical reasons, but it was written by Sejal Zota], a former colleague discussed Padilla v. Kentucky, 130 S. Ct. 1473 (Mar. 31, 2010), a U.S. Supreme Court decision dealing with ineffective assistance of counsel in connection with advice regarding the immigration consequences of a plea. In Padilla, after pleading guilty to a charge of transporting a large amount of marijuana, the defendant, a lawful permanent resident of the United States for more than forty years, faced deportation. He challenged his plea, arguing that his counsel rendered ineffective assistance by failing to inform him that the plea would result in mandatory deportation and by incorrectly informing him that he did not have to worry about his immigration status because he had been in the country for a long time. The Court concluded that when, as in the present case, “the deportation consequence [of a plea] is truly clear,” counsel must correctly inform the defendant of this consequence. However, the Court continued, where deportation consequences of a plea are “unclear or uncertain[] [t]he duty of the private practitioner . . . is more limited.” It continued: “When the law is not succinct and straightforward . . . , a criminal defense attorney need do no more than advise a noncitizen client that pending criminal charges may carry a risk of adverse immigration consequences.” The Court declined to rule whether the defendant was prejudiced by his lawyer’s deficient conduct.

Padilla has generated a lot of post-conviction litigation nationally. And in North Carolina it’s no different—numerous motions for appropriate relief have been filed alleging that counsel was ineffective under Padilla by failing to properly advise defendants regarding the immigration consequences of their pleas. For defendants whose convictions became final prior to Padilla, retroactivity is a preliminary issue presented by those motions. As I discuss in more detail in a bulletin available here, under federal law a new rule of criminal procedure does not apply retroactively unless it is a watershed rule of criminal procedure. Put in visual form, retroactivity analysis for Padilla follows this path:

A number of courts in other jurisdictions have addressed the issue of whether Padilla is retroactive and a split of authority is emerging at the appellate level. Compare United States v. Hong, __ F.3d __, 2011 WL 3805763 (10^th Cir. Aug. 30, 2011) (Padilla is a new rule but not a watershed rule and thus is not retroactive), and Chaidez v. United States, __ F.3d __, 2011 WL 3705173 (7^th Cir. Aug. 23, 2011) (as a new rule, Padilla is not retroactive; because the parties agreed that the rule was not a watershed rule of criminal procedure, the court did not address that issue), with United States v. Orocio, 645 F.3d 630 (2d. Cir. 2011) (Padilla is not a new rule and thus applies retroactively), and Commonwealth v. Clarke, 949 N.E.2d 892 (Mass. 2011) (same). The North Carolina appellate courts have not yet dealt with the issue. But given the post-conviction motions before the trial bench, it is only a matter of time before we see a decision. When we do, I’ll post an update.

Category: Procedure, Uncategorized | Tags: immigration, ineffective assistance of counsel, padilla, retroactivity

Court of Appeals Holds that Harbison Survives Nixon

Posted on July 20, 2010 by Jessica Smith

In State v. Harbison, 315 N.C. 175 (1985), the North Carolina Supreme Court held that when defense counsel admits the defendant’s guilt to the jury without the defendant’s consent per se ineffective assistance of counsel occurs. The Harbison Court reasoned that when counsel admits guilt without consent, it is essentially the same as entering a guilty plea on the defendant’s behalf without the defendant’s consent. It concluded: “ineffective assistance of counsel, per se in violation of the Sixth Amendment, has been established in every criminal case in which the defendant’s counsel admits the defendant’s guilt to the jury without the defendant’s consent.” Id. at 180.

Harbison claims differ from the more garden-variety attorney-error ineffective assistance of counsel claims, commonly called Strickland claims. Such a claim might allege, for example, that counsel’s conduct was deficient by failing to interview a key witness or by failing to object to inadmissible evidence. Strickland claims are evaluated under a two-pronged test, requiring the defendant to show both deficient performance and prejudice. See Strickland v. Washington, 466 U.S. 668 (1984). A Harbison claim thus is easier to prove than a Strickland claim; for a Harbison claim the defense need only establish an admission of guilt; no showing of prejudice is required.

In 2004, the United States Supreme Court decided Florida v. Nixon, 543 U.S. 175 (2004), a capital case. Applying the Sixth Amendment, Nixon held that when a defendant alleges ineffective assistance of counsel due to an unconsented-to admission of guilt, the claim should be analyzed under the Strickland attorney error standard. As such, it called Harbison into question. However, in State v. Maready, __ N.C. App. __ (July 6, 2010), the North Carolina Court of Appeals recently held that Nixon did not affect the North Carolina Harbison rule.

In Maready, the defendant faced an array of charges stemming from impaired driving and a death in connection with a vehicle collision. The defendant was convicted of, among other things, second-degree murder and two counts of assault with a deadly weapon. He appealed these convictions asserting a Harbison claim based on the following statements made by defense counsel during closing argument:

We do have the two misdemeanor assaults. . . . We don’t contest those. They are inclusive in the events that have significant issues associated with them, but we don’t contest those. And you can go and make your decisions accordingly. . . . [Defendant] holds absolute – holds responsibility for [the death of the victim]. I just argue it’s not murder. It’s Involuntary Manslaughter.

Additionally, counsel stated “that . . . [D]efendant’s impaired driving proximately caused the victim’s death. That’s true. [Defendant’s] guilty of that and should be found guilty of that.” Counsel also stated: “[Defendant’s] already admitted to you guilt . . . to . . . Assault with a Deadly Weapon times two[.]” Notwithstanding these statements, the trial court never asked the defendant whether he had agreed to counsel’s admissions of guilt as to these charges.

Considering Nixon’s effect on the Harbison rule, Maready found Nixon distinguishable on grounds that it was a capital case and the case before it was non-capital. The court also considered itself bound by Harbison because post-Nixon decisions by the North Carolina Supreme Court and Court of Appeals continued to apply Harbison. On these points, the concurring opinion disagreed. Finally, the court stated, in a footnote, that Nixon did not constrain the State’s ability to set a state constitutional protection above the federal floor. This language suggests that the court views Harbison as grounded in the state constitution, another point on which the concurring opinion disagreed. Having found Nixon inapplicable, the court held that a Harbison error occurred because the defendant never gave his explicit consent to counsel to admit guilt to involuntary manslaughter or to the two counts of assault with a deadly weapon. The court rejected the notion that the defendant’s implicit consent could satisfy the Harbison rule.

Maready makes clear that Harbison is alive and well in North Carolina. I thus continue to advise judges to ask–before both opening and closing statements–whether counsel plans to admit guilt. If so, the trial judge should determine, on the record, whether the defendant consents to this strategy. Defense counsel may not proceed with this strategy unless the defendant gives explicit consent. If counsel unexpectedly admits guilt during trial, the trial judge should excuse the jury and determine, on the record, whether the defendant consents to the admission. If the defendant does not consent, a mistrial may be required.

Category: Procedure, Uncategorized | Tags: admission of guilt, harbison, ineffective assistance of counsel, maready, nixon

Failure to Request a Jury Instruction on Informants

Posted on July 13, 2010 by Jeff Welty

I was catching up on the Fourth Circuit’s recent opinions this weekend when I came across United States v. Luck. It raises some interesting issues that are not specific to federal court, so I thought I’d put together a post about it.

The defendant in Luck was charged with drug and gun crimes. The government’s evidence came primarily from two informants: one was working off charges, while the other was working to help the first, and for money. Although one of the informants made two supervised drug purchases from the defendant, she was not searched thoroughly prior to the purchases. There was virtually no other corroboration of the informants’ testimony. Nonetheless, the defendant was convicted and sentenced to 444 months in prison.

The case was affirmed on direct appeal. The defendant then sought collateral review, arguing in pertinent part that his trial lawyer was ineffective for failing to request a jury instruction on informant testimony, i.e., an instruction that informants’ testimony “must be examined and weighed by the jury with greater care than the testimony of an ordinary witness” because of their particular interests and biases. The federal district court denied relief on this claim, but the Fourth Circuit reversed, vacating the defendant’s convictions.

The court began by suggesting, but not actually holding, that such an instruction should be given as a matter of course in many cases: “Among the other circuits that have considered this question, there is a consensus that an informant instruction is necessary when the informant’s testimony is uncorroborated by other evidence.” Although the court found this consenus “persuasive,” implying that judges should give such instructions sua sponte in some instances, it held only that defense counsel performed deficiently in not requesting such an instruction in the case at bar, given that counsel’s strategy focused on the informants’ motives and lack of credibility.

The court then discussed whether the defendant was prejudiced by counsel’s failure to request the instruction. It concluded that the district court likely would have given the instruction if requested, and that even though the district court gave a general instruction on witness credibility, including bias, an informant instruction would have been “more effective[]” and would have “alert[ed] jurors to the potentially unique problems that inhere where an individual is paid to inculpate a defendant.” Because the government’s case depended so heavily on the informants’ testimony, the court found a reasonable probability that an informant instruction would have changed the outcome of the trial. One judge dissented on this point; he would have held that even if counsel’s performance was deficient, there was no prejudice because the jury was clearly aware, through defense counsel’s cross-examination and closing argument, of the informants’ motives.

Turning to North Carolina law, there is, of course, a pattern jury instruction for informants. N.C.P.I. Crim — 104.30, entitled “Informer or Undercover Agent,” reads as follows:

You may find from the evidence that a State’s witness is interested in the outcome of this case because of the witness’ activities as an [informer] [undercover agent]. If so, you should examine such testimony with care and caution in light of that interest. If, after doing so, you believe the testimony in whole or in part, you should treat what you believe the same as any other believable evidence.

A couple of asides. First, it strikes me as odd that this instruction covers undercover officers as well as informants, given that officers generally are not considered interested witnesses. State v. McQueen, 181 N.C. App. 417 (2007). What makes undercover officers more interested than uniformed ones? However, by its terms, the instruction clearly does apply to undercover officers, and failure to give the instruction in a case involving an undercover officer was held to be reversible error in State v. Black, 34 N.C. App. 606 (1977). Second, this instruction is not as strong as the instruction discussed in Luck. It tells the jury only to view an informant’s testimony with “care,” not with “greater care than the testimony of an ordinary witness[].” That makes me wonder whether defense lawyers in some cases might reasonably request an instruction that is more robust than the pattern.

In any event, Black and other cases make it perfectly clear that the instruction must be given when requested and appropriate. Is failure to request the instruction when appropriate then ineffective assistance of counsel? I don’t think there’s a North Carolina case on point, but the reasoning of Luck is persuasive: in at least in some circumstances, the answer may well be yes.

Category: Procedure, Uncategorized | Tags: effective assistance of counsel, ineffective assistance of counsel, informants, jury instrcutions

A New Constitutional Mandate for Defense Counsel

Posted on April 1, 2010 by Jeff Welty

by School of Government Immigration Law Specialist Sejal Zota

Is defense counsel constitutionally obligated to inform a noncitizen criminal defendant whether his guilty plea carries a risk of deportation? Yesterday, the United States Supreme Court said yes in a case called Padilla v. Kentucky.

In Padilla, the petitioner—a lawful permanent resident (green card holder) for over 40 years and Vietnam veteran—faced drug-distribution charges in a Kentucky trial court. His attorney advised him to plead guilty in exchange for a lighter sentence and not “to worry about [deportation] since he had been in the country so long.” Padilla took this advice. When he learned that his lawyer’s immigration advice was wrong and he would face deportation for his conviction, he sought to overturn it by arguing that he would have gone to trial but for counsel’s incorrect advice. The Supreme Court of Kentucky rejected his claim, holding that advice about deportation is a “collateral consequence” of conviction, and outside the scope of representation required by the Sixth Amendment.

Holding that deportation is an integral part of the penalty that may be imposed on noncitizen criminal defendants, the United States Supreme Court reversed. The Court found that the protections of Strickland v. Washington, 466 U.S. 688 (1984)—which entitle criminal defendants to effective assistance of counsel before deciding to plead guilty—apply to advice regarding deportation. The Court also found the Kentucky court’s distinction between direct and collateral consequences was beside the point.

In evaluating Padilla’s ineffectiveness claim, the Court found that counsel’s representation fell below an objective standard of reasonableness under prevailing professional norms—“This is not a hard case in which to find deficiency: The consequences of Padilla’s plea could be easily determined from reading the removal statute, his deportation was presumptively mandatory, and his counsel’s advice was incorrect.” Clear and unambiguous immigration law made the crime of drug distribution to which Padilla pled guilty a basis for deportation of noncitizens because it relates to a nontrivial possession of a controlled substance.

The Court’s ruling yesterday did not wholly resolve Padilla’s claim. The Court declined to address whether he had been prejudiced by his attorney’s actions and remanded for further proceedings. In assuaging a “floodgates” concern, the Court held that to establish prejudice, a reviewing court must be convinced that a petitioner’s decision to reject a plea bargain would have been rational under the circumstances.

What’s interesting about this case is the Court could have limited the holding to “affirmative misadvice”— finding representation may be constitutionally deficient only when defense counsel actually provides advice about deportation and that advice is patently wrong. Before yesterday, many state and federal courts had long held such a view. But instead, the Court’s ruling recognized the seriousness of deportation as a consequence of a criminal plea, and now obligates defense counsel to inform noncitizen clients about the risk of deportation. The Court has given defense counsel across the Nation an important responsibility that many had already undertaken in cooperation with immigration attorneys. But it will not always be an easy task.

“When the deportation consequences are truly clear, the duty to give correct advice is equally clear.” As someone who regularly consults in this area, I can tell you that determining deportation consequences can be complex stuff. Deportation may depend on various factors such as a client’s immigration status; the length of sentence; whether the state offense falls under broad grounds of deportation like crimes involving moral turpitude, whether a state disposition will be treated as a conviction for immigration purposes … you get the picture. It may often be the case that the deportation consequences of a particular plea are unclear to defense counsel. In those instances, the Court places a lesser burden on defense counsel: when the deportation consequences of a particular plea are unclear or uncertain, “defense counsel need do no more than advise a noncitizen client that pending criminal charges may carry a risk of adverse immigration consequences.”

Fortunately, many defender offices around the country, including in North Carolina, are ahead of the curve. Many already train staff on immigration consequences with the help of networks of experts. Foreshadowing the Padilla decision, the School of Government has already published a manual on the Immigration Consequences of a Criminal Conviction in North Carolina. It appears that the manual may become required reading for the criminal defense bar. I am also available to help public defenders and assigned counsel determine the immigration consequences of convictions.

Category: Procedure, Uncategorized | Tags: immigration, ineffective assistance of counsel, padilla

Spisak

Posted on January 12, 2010 by Jeff Welty

Consider the following excerpts from a penalty phase closing argument in a capital case:

“[D]on’t look to [the defendant] for sympathy, because he demands none. And, ladies and gentlemen, when you turn and look at [the defendant], don’t look for good deeds, because he has done none. Don’t look for good thoughts, because he has none.”
“[Y]ou can smell almost the blood. You can smell, if you will, the urine. You are in a bathroom [where one of the victims was killed], and it is death, and you can smell the death . . . and you can feel, the loneliness of that railroad platform . . . and we can all know the terror that [the victim] felt when he turned and looked into those thick glasses and looked into the muzzle of a gun that kept spitting out bullets . . . And we can see a relatively young man cut down with so many years to live, and we could re-member his widow, and we certainly can remember looking at his children . . . There are too many family albums. There are too many family portraits . . . that have too many empty spaces.”
“[D]on’t look to [the defendant] with the hope that he can be rehabilitated, because he can’t be. . . . [H]e is never going to be any different.”
The case has “all the aggravating circumstances you [could] ever want.”

You might wonder whether such a closing argument is proper, and particularly, whether the prosecutor’s use of the “you can smell the blood” passage improperly invites the jurors to put themselves in the victims’ place. But the above excerpts are from the closing argument for the defendant in Smith v. Spisak, decided today by the Supreme Court. You can read the full transcript of the closing argument here.

Spisak is a case from Ohio. The defendant, Frank Spisak, is a white supremacist who killed three people, and tried to kill two more, in Cleveland over the course of several months. He admitted the killings at trial, proudly describing them as part of a war for the survival of the Aryan race, and indicated that if he were able to escape from jail, he would “continue to inflict the maximum amount of damage on the enemies” as he could. Media accounts indicate that he also wore a Hitler-style mustache and shouted “Heil Hitler!” during trial.

He was convicted and sentenced to death, and eventually filed a habeas petition in federal court, alleging inter alia that his lawyer’s closing argument at the penalty phase was so bad that it violated his Sixth Amendment right to the assistance of counsel. The district court disagreed, but the Sixth Circuit reversed. Spisak v. Mitchell, 465 F.3d 684 (6th Cir. 2008). The appellate court said that “trial counsel did very little to offset the negative feelings that his own hostility and disgust for Defendant may have evoked in the jury. Instead . . . counsel further denigrated Defendant and even went so far as to tell the jury that Defendant was undeserving of mitigation.” It found that this breached counsel’s duty of loyalty to Spisak, a breach that was compounded when the lawyer effectively told the jury that either life or death would be appropriate verdicts.

The Supreme Court unanimously reversed. In order for a lawyer’s performance to constitute ineffective assistance of counsel, it must (1) be deficient, and (2) prejudice the defendant, in that there is a reasonable probability that it affected the outcome of the trial. The Court “assume[d]” that the closing argument was deficient, but held that the heinousness of the crimes, Spisak’s own inflammatory testimony, and the lack of any real mitigating evidence beyond the mental illness that counsel did reference at times in the closing argument, a better closing would not have changed the outcome. Justice Stevens concurred, stating that the argument was “thoroughly egregious,” a “catastrophe,” and “shares far more in common with a prosecutor’s closing than with a criminal defense attorney.” But he agreed that “even the most skillful of closing arguments—even one befitting Clarence Darrow—would not have created a reasonable probability of a different outcome in this case.”

For those interested in further reading about the facts of this unusual case, a somewhat tawdry story about the case is here; what purports to be a letter from Spisak about his transsexualism is here.

Category: Procedure, Uncategorized | Tags: closing argument, ineffective assistance of counsel, spisak

Porter and Ineffective Assistance of Counsel at Capital Sentencing Hearings

Posted on December 3, 2009 by Jeff Welty

The United States Supreme Court recently decided Porter v. McCollum, a capital case in which the defendant claimed that his lawyer performed ineffectively at the penalty phase of his trial. It’s interesting for a couple of reasons, including the strong language it contains about the mitigating value of a defendant’s military service.

George Porter shot and killed his ex-girlfriend and her new boyfriend. He was charged, in a Florida state court, with two counts of first-degree murder. He elected to represent himself during the guilt phase of the trial and was convicted on both counts. He then asked that his standby counsel represent him during the penalty phase. Although the lawyer had a month to prepare for the hearing, he had never represented a defendant in a capital sentencing proceeding, and he did very little. He met with Porter just once, “did not obtain any of Porter’s school, medical, or military service records or interview any members of Porter’s family,” and ignored indications in competency evaluations that Porter’s childhood had been troubled and that his military service had been traumatic. As a result, his penalty phase presentation was limited to a single witness — Porter’s ex-wife — and a deposition excerpt. “The sum total of the mitigating evidence was inconsistent testimony about Porter’s behavior when intoxicated and testimony that Porter had a good relationship with his son.” The jury recommended death for both crimes, but the trial judge imposed a sentence of death only for the murder of the ex-girlfriend, opting to impose a life sentence for the other killing.

In post-conviction proceedings, Porter argued that his lawyer had performed ineffectively. His claim was rejected by the Florida courts, which found that any deficient performance by the lawyer did not prejudice Porter. On federal habeas, the district court granted relief, but the Eleventh Circuit reversed, concluding that the Florida courts’ ruling on the prejudice issue was reasonable.

The Supreme Court reversed per curiam — in a brief, unanimous, and unsigned opinion. That’s pretty strong medicine, the same kind that the Court sometimes uses when it reverses a Ninth Circuit decision the other way (as is recently did in Wong v. Belmontes). The Court had little difficulty finding that Porter’s lawyer performed deficiently. It also found that Porter was prejudiced, in light of what it viewed as strong mitigating evidence that the lawyer should have discovered and presented, such as evidence that Porter had been physically abused by his father, and evidence of Porter’s mental abnormalities, which made it difficult for him to read and write and contributed to his limited education.

But the category of mitigating evidence on which the Court spent the most time, by far, was Porter’s military service in the Korean War. Though blemished by several periods of going absent without leave (AWOL), Porter’s service was nonetheless distinguished: he won two Purple Hearts and fought in two of the war’s bloodiest battles, which are described in some detail in the opinion. Porter’s service was also traumatic, contributing to a drinking problem and resulting in nightmares so vivid that he would try to climb the walls of his bedroom with knives.

The language that the Court used to describe the mitigating value of Porter’s military service was strong, and may be of relevance beyond the capital context. For example, the Court stated that “[o]ur Nation has a long tradition of according leniency to veterans in recognition of their service, especially for those who fought on the front lines as Porter did.” In a state that is home to so many military personnel and military veterans, this is worth noting.

You can read more about this case in posts or articles at Sentencing Law and Policy, SCOTUSblog, or the New York Times.

Category: Sentencing, Uncategorized | Tags: capital sentencings, ineffective assistance of counsel, military service, porter

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