Reeves v. Alabama, 138 S. Ct. 22

Matthew Reeves was convicted of capital murder in Alabama and sentenced to death; he raised ineffective-assistance claims in a Rule 32 postconviction petition.
Trial counsel sought and obtained court funding and an appointment order to retain neuropsychologist Dr. John R. Goff to evaluate Reeves for intellectual disability, but never contacted or hired him.
At trial counsel presented limited mitigation: mother's testimony, a partial verbal IQ assessment from Dr. Ronan (court-appointed for competency), and a few other witnesses; the jury quickly recommended death (10–2).
In postconviction proceedings Reeves presented Dr. Goff’s full neuropsychological testing (concluding Reeves is intellectually disabled), a mitigation evaluation by Dr. Salekin, and Dr. Ronan’s affidavit describing limits of her prior evaluation.
The Alabama Court of Criminal Appeals affirmed denial of relief solely because Reeves did not call his former attorneys to testify at the evidentiary hearing, treating that omission as fatal to rebutting the presumption of reasonable performance.
The Supreme Court denied certiorari; Justice Sotomayor (joined by Justices Ginsburg and Kagan) dissented, arguing the state court’s per se rule requiring counsel testimony conflicts with Strickland.

Issue	Reeves' Argument	Alabama/State's Argument	Held
Whether a state court may impose a per se rule that a petitioner must call trial counsel to testify to overcome Strickland's presumption	The state court erred: Strickland requires an objective review of the full record and does not mandate counsel’s testimony; other record evidence suffices	The Court of Criminal Appeals required counsel testimony and found Reeves failed to overcome the presumption because he did not call his attorneys	SCOTUS denied cert; Sotomayor dissented, concluding the state court applied an improper per se rule and would have granted certiorari and reversed
Whether trial counsel rendered deficient performance by failing to obtain/use a neuropsychologist evaluation for mitigation	Reeves: counsel were ineffective for obtaining funding but not using it to secure an expert or to present intellectual-disability mitigation	State: Reeves failed to prove counsel’s decisions were unreasonable (pointing to lack of counsel testimony and overall burden)	State courts rejected ineffective-assistance claims; Justice Sotomayor faulted the courts for not evaluating the full record in light of Strickland

Strickland v. Washington, 466 U.S. 668 (establishes two-prong ineffective-assistance test and presumption of reasonable professional judgment)
Wiggins v. Smith, 539 U.S. 510 (courts must review counsel performance objectively using the whole record; limited investigation may be unreasonable)
Porter v. McCollum, 558 U.S. 30 (per curiam) (postconviction review looks to the full record to assess counsel’s investigation and presentation of mitigation)
Massaro v. United States, 538 U.S. 500 (ineffective-assistance claims need not always await collateral review; some claims are apparent on the record)