(CN) — The 11th Circuit erred in finding an Alabama state court had applied a blanket rule that a prisoner will always lose a habeas claim of ineffective assistance of trial counsel if they don’t call their attorneys to the stand to testify about their strategic decisions, the Supreme Court ruled Friday.
In an unsigned 6-3 majority opinion, the high court said the Alabama Court of Criminal of Appeals had correctly employed a case-specific analysis in rejecting Alabama death row inmate Matthew Reeves' claims that his trial counsel had deficiently represented him because they should have hired a neuropsychologist to develop mitigating evidence he is intellectually disabled.
"The Eleventh Circuit, however, recharacterized this case-specific analysis as a 'categorical rule' that any prisoner will always lose if he fails to call and question 'trial counsel regarding his or her actions and reasoning,'" the 12-page majority opinion states.
The majority, made up of the high court’s six conservative judges, chastised the 11th Circuit for reviving Reeves' claims, reversed and remanded the case.
Reeves was sentenced to death for the Nov. 27, 1996 murder of Willie Johnson.
Then 18, Reeves and his friends had gone out that day looking for people to rob. Their first target was a drug dealer in a neighboring town, but their car broke down, according to the case record.
Johnson came by in his pickup truck and offered to give them a ride and tow their car to Reeves’ house.
When they arrived at the home, Reeves, who was riding in the bed of the truck, stuck a shotgun through the rear window of the cab and fatally shot Johnson in the neck. Reeves then told his friends to go through Johnson’s pockets and they stole his money.
Reeves showed no remorse for the murder and in fact boasted about it throughout the rest of the day. And that night at a party he made up a dance in which he pretended to pump a shotgun and jerked his body around mocking the way Johnson had died.
After Reeves was charged with murder, his attorneys successfully lobbied the trial court for funding to hire neuropsychologist Dr. John Goff to evaluate Reeves and prepare mitigation evidence to convince the jury not to recommend the death penalty.
But Reeves’ defense team ultimately chose not to hire Goff after they obtained other records that showed Reeves had a troubled childhood. He was expelled from school for fighting and misbehaving and referred to counselors for behavioral issues, but he had been denied special education services for intellectual disability. His counsel also learned he had earned certificates in welding, masonry and auto mechanics, and a psychologist they had hired to evaluate Reeves determined he was not intellectually disabled.
The trial judge sentenced Reeves to death on the recommendation of the jury.
At a hearing on his postconviction appeal in state court, Reeves’ new counsel called Goff to the stand. Goff testified he believed Reeves was intellectually disabled, citing a controversial theory called the Flynn Effect involving the inflation of IQ scores over time, and said the theory called for adjusting Reeves’ score down into the 60s.
But an expert called by the state who evaluated Reeves found no evidence he was intellectually disabled, pointing to the fact Reeves had made $2,000 a week as a leader of a crew of drug dealers.
The trial court denied relief and the Alabama Court of Appeals affirmed. After the Supreme Court declined to review the case, Reeves filed a federal habeas case. The district court denied relief, but the 11th Circuit reversed in part.
The Atlanta-based appellate court agreed Reeves had failed to prove he is intellectually disabled, but held his lawyers were constitutionally deficient for not developing more evidence of intellectual disability, and said the failure could have changed the outcome of his capital murder trial.
The Supreme Court reversed that decision Friday and remanded the case, pursuant to a petition for review from Alabama Department of Corrections Commissioner Jefferson Dunn.
It found that in analyzing the Alabama Court of Appeals’ decision denying relief, the 11th Circuit had misinterpreted the state court’s ruling as foreclosing any ineffective-assistance-of-trial-counsel claims not backed by testimony from the trial attorneys.
In his postconviction proceedings in state court, Reeves opted not to call his attorneys to testify about their decision not to hire Dr. Goff to evaluate him.
“The court did not merely say, as the Eleventh Circuit wrongly suggested, that Reeves’ ‘failure to call his attorneys to testify was fatal to his claims.’ . . . Rather, the opinion prefaced this quote with an important qualifier—'In this case,’” the majority’s unsigned opinion states.
In a 14-page dissent, Justice Sonia Sotomayor, joined by Justice Elena Kagan, said the majority’s decision continues a troubling trend in which the “court strains to reverse summarily any grants of relief to those facing execution.”
Justice Stephen Breyer also dissented from the majority opinion but did not join his fellow liberal colleagues’ dissenting opinion.
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