Walker v. McQUIGGAN
2011 U.S. App. LEXIS 18449
6th Cir.2011Background
- Walker was convicted of first-degree murder and felony-firearm in Michigan; trial counsel did not pursue an insanity defense despite Walker’s mental illness history.
- Counsel chose a mixed accident/self-defense/intoxication strategy, relying on a Fields competency/insanity evaluation which favored trial likely outcomes.
- Eyewitness and forensic evidence at trial supported the prosecution; none suggested Walker was legally insane at the time.
- Walker had a long history of severe mental illness, hospitalizations, and inconsistent medication, known to trial counsel.
- Michigan courts largely held counsel’s performance was not prejudicial based on the insufficiency of an insanity defense, prompting a habeas petition in federal court.
- The Sixth Circuit ultimately reversed the district court, granting habeas relief and ordering release unless re-trial occurred.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was counsel's failure to investigate insanity deficient? | Walker: counsel failed to investigate insanity despite known illness. | Winters: strategy reasonable; relied on Fields; no independent evaluation sought. | Yes; performance deficient. |
| Did the failure prejudice Walker under Strickland in habeas review? | Walker: substantial defense existed; insanity would alter verdict. | State court required near-certain acquittal; insufficient prejudice. | Prejudice established; habeas relief warranted. |
| Did the state court improperly apply Strickland in weighing prejudice? | Totality of evidence favored insanity defense; not limited to acquittal probability. | Court weighed evidence as to likelihood of acquittal; proper under Strickland. | State court misapplied Strickland. |
| Did AEDPA deference bar relief, or permit it given unreasonable findings? | State court unreasonably determined facts and misapplied federal law. | AEDPA standard highly deferential; no unreasonable application shown. | State court decision unreasonable; relief granted. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes deficient performance and prejudice prongs)
- Williams v. Taylor, 529 U.S. 362 (2000) (advocates totality of mitigation evidence in prejudice analysis)
- Harrington v. Richter, 131 S. Ct. 770 (2011) ( AEDPA review is highly deferential; fairminded disagreement possible)
- Knowles v. Mirzayance, 556 U.S. 111 (2009) (insanity defense abandonment requires showing substantial prejudice)
- Ake v. Oklahoma, 470 U.S. 68 (1985) (psychiatry is not an exact science; jury factfinding on insanity)
- Premo v. Moore, 131 S. Ct. 733 (2011) (habeas court must consider information available to counsel)