Allen v. Lawhorn
178 L. Ed. 2d 575
SCOTUS2010Background
- Lawhorn was sentenced to death in Alabama in 1989 for capital murder; his counsel waived closing argument in the sentencing phase.
- On federal habeas review, the Eleventh Circuit held the waiver prejudicial under Strickland; it reversed as to the sentence but not the conviction.
- The district court had vacated the conviction and sentence; the Eleventh Circuit affirmed with respect to prejudice, applying AEDPA deference issues.
- The State petitioned for certiorari; it challenged only the determination of prejudice, not the existence of deficiency.
- AEDPA requires deference to state court rulings on factual and legal conclusions unless they are contrary to or an unreasonable application of clearly established federal law.
- The dissent argues the Alabama courts’ conclusion that closing argument would have little impact was reasonable and within AEDPA’s deferential standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| AEDPA deference applied to prejudice ruling | Lawhorn argues Eleventh Circuit failed to apply AEDPA deference properly. | Lawhorn concedes deference but contends it was applied there. | AEDPA deferential standard applied; deference due to state court ruling. |
| Prejudice under Strickland for closing argument | Lawhorn asserts there was a reasonable probability the outcome would differ with closing argument. | Lawhorn contends closing argument could have altered juror views and prejudiced outcome. | Not a reasonable probability; Alabama court reasonable under Strickland. |
| Whether hypothesized closing argument could change outcome | Lawhorn identifies potential themes that closing could emphasize to sway jurors. | Lawhorn argues such arguments would have changed the verdict; statements would be speculative. | Speculation cannot satisfy Strickland prejudice; court within reasonable bounds. |
| Scope of federal review for state-court decisions in capital sentencing | Lawhorn alleges pattern of improper interference with state justice by federal review. | State emphasizes need for federal review as allowed by AEDPA framework. | Viewed as an improper interference; court should not revise state judgments absent unreasonable application. |
Key Cases Cited
- Renico v. Lett, 559 U. S. 766 (2010) (highly deferential standard for evaluating state-court rulings under AEDPA)
- Knowles v. Mirzayance, 556 U. S. 111 (2009) (greater latitude for state courts in applying general Strickland standards)
- Schriro v. Landrigan, 550 U. S. 465 (2007) (AEDPA deference principles for state-court decisions)
- Woodford v. Visciotti, 537 U. S. 19 (2002) (per curiam; reaffirmed deferential review of state-court rulings)
- Williams v. Taylor, 529 U. S. 362 (2000) (AEDPA deference; limits on federal review of state court decisions)
- Strickland v. Washington, 466 U. S. 668 (1984) (establishes standard for ineffective assistance of counsel)