Rompilla v. Beard
Significance: The Supreme Court reaffirmed that criminal defendants have a right to effective assistance of counsel and also provided additional clarification about practices that constitute ineffectiveness.
Rompilla v. Beard expanded and clarified the principles of Strickland v. Washington (1984), recognizing that the Sixth Amendment's right to counsel can be infringed by an incompetent lawyer. In overturn a verdict, Strickland required that a defendant must demonstrate a “reasonable probability” that except for the deficiency the outcome would have been different. Although it was difficult for defendants to meet this standard, one defendant had his conviction overturned in Wiggins v. Smith (2003), which held that a defense attorney's failure to investigate his troubled background as mitigating evidence amounted to ineffective assistance of counsel. A Pennsylvania jury found Ronald Rompilla guilty of first-degree murder. At the sentencing phase, the prosecutor informed the jury of Rompilla's previous convictions of assault and rape, which were aggravating factors. The jury sentenced him to death. Rompilla then obtained a new lawyer, who appealed the verdict with the argument that the earlier defense attorney had failed to present mitigating evidence that might have produced a different sentence. Although a district court rejected the argument, the Third Circuit Court of Appeals ruled in Rompilla's favor. The Supreme Court agreed with the Third Circuit's decision. Speaking for a 5-4 majority, Justice David H. Souter argued that Pompilla's trial attorney had acted ineffectively when not looking for mitigating circumstances, especially his early life experiences with mental illness, alcoholism, and abuse. The attorney had even failed to read the file on Rompilla's criminal record, which contained evidence of these mitigating considerations. In conclusion, Souter noted that knowledge of this evidence might have influenced the jury's perception of culpability, so that there existed a “likelihood of a different result” with effective counsel.