Case: Rompilla v. Beard (2005)
Citation: Rompilla v. Beard, 545 U.S. 374 (2005).
Facts of the Case
On January 14, 1988, James Scanlon was found dead in a store. Scanlon’s body was stabbed with a knife and after that set on fire. Rompilla admitted that he committed the crime but soon addressed the new court to review the case that did not involve important mitigating factors.
Rompilla (the petitioner) was sentenced to the death penalty for committing murder and several other crimes.
New lawyers of the defendant stated that not all mitigating evidence was presented in the court, which could have affected the jury’s decision. The Pennsylvania Supreme Court affirmed the court’s decision, while the District Court found that the State Supreme Court was not reasonable as Rompilla’s troubled childhood, alcohol abuse history, and mental illness were not taken into account. The Third Circuit decided that the decision of the State Supreme Court was reasonable as the counsel examined the major mitigating factors, including previous felony history, and reasonably assumed that further investigation was unnecessary and could be a waste of time and other resources.
Major Issues Decided
The major issues were concerned with the extent to which the council had to review mitigating factors. The principle of reasonableness is central to the case.
Appellant & Position
Rompilla and his new lawyers stressed that counsel did not pay enough attention to important mitigating factors, including the mental illness of the defendant, his previous felony records, his troubled childhood, and substance abuse history. The appellant stressed that the jury would have found him not guilty if these factors had been presented in the court.
Appellee & Position
The US Supreme Court decided that the defense counsel failed to pay sufficient attention to important details and examine all the mitigating factors to the fullest. The court stressed that although the defendant and the family could be insufficiently cooperative, the defendant’s defense counsel was responsible for making reasonable efforts to examine all possible mitigating factors.
Synopsis of Majority Opinion
The majority concluded that the defense counsel did not make reasonable efforts to examine all mitigating factors and present them in the court, which could have influenced the jury’s decision. The majority decided that it was obvious that the defendant’s previous felony history would be the major aggravating factor. Rompilla’s lawyers had to make reasonable efforts and examine all the details of his previous convictions.
The majority also concluded that the court failed to find the lawyers’ examination inadequate, which led to certain prejudice. This prejudice led to the jury’s decision and the corresponding sentence. It is also emphasized that the defendant was not cooperative, and this lack of cooperation was the background for a more detailed investigation of meaningful aspects of the case.
Justices in Majority
Souter, O’Connor, Breyer, Stevens, Ginsburg
Synopsis of Concurrent Opinion (if any)
Justice O’Connor had a concurring opinion and stressed that there were three factors that made the defense counsel’s decision not to examine in more detail Rompilla’s previous felony history unreasonable. The attorneys knew that prior conviction would become central to the prosecutor’s case. This circumstance was enough to invest more time in the examination of the case.
The defense focused on the residual doubt argument as the central mitigating factor, but the previous felony was very similar to the case in question. The attorneys had to pay more attention to both cases to find additional circumstances (for instance, mental illness). The attorneys did not fully ignore the previous case but failed to obtain all the necessary materials on time.
- Justices in Concurrence: O’Connor
Synopsis of Minority Opinion
The minority believed that the defense counsel’s effort was reasonable. One of the central arguments was that the defendant (not the State) is fully responsible for bringing out all mitigating factors. However, the defendant and his family were not cooperative enough, which makes them totally responsible for the jury’s decision.
The attorneys addressed three mental health professionals who revealed their opinion concerning the defendant’s mental health. Therefore, there was no need to examine previous cases in such details and focusing on mental illnesses that had been identified. It was stressed that the counsel’s resources were limited, and it was important to use them reasonably, which was made during the case in question.
- Justices in Minority: Kennedy, Thomas, Scalia, Rehnquist
Reference
Rompilla v. Beard, 545 U.S. 374 (2005).