Supreme Court, Case Study Example

Abstract

The paper reviews a recent U.S. Supreme Court Case. The summary of the case is provided. The paper evaluates the significance of the case and the quality of the court’s decision.

Holly Wood, Petitioner v. Richard F. Allen, Commissioner, Alabama Department of Corrections, et al.

January 20, 2010

The parties involved in the case include Holly Wood, the petitioner who in 1993 broke into his ex-girlfriend’s home and shot her in the head and face while she was lying in bed; the victim died on arrival at the hospital (Wood v. Allen, 2010). The respondent Richard F. Allen is the Commissioner of Alabama Department of Corrections, where the petitioner awaits the execution of the death penalty (Wood v. Allen, 2010).

In 1993, Holly Wood broke into his ex-girlfriend’s house and shot her twice – in the head and face, and the victim was pronounced dead at the arrival to the hospital (Wood v. Allen, 2010). Wood was charged with capital murder at a first-degree burglary (Wood v. Allen, 2010). In Alabama state court, Wood was represented by three court-appointed attorneys, of whom two had significant trial experience and the third one, Kenneth Trotter, had been admitted to the bar for several months at the time he was appointed to represent Wood in court (Wood v. Allen, 2010). Wood was convicted at the guilt phase of trial and was recommended a death sentence – later the judge confirmed the sentence and imposed the death penalty (Wood v. Allen, 2010). Wood petitioned for state postconviction relief, and argued that he was mentally retarded and thus was not eligible for the death penalty (Wood v. Allen, 2010). Wood wanted to prove that his trial counsel had failed to investigate and present evidence of his mental retardation (Wood v. Allen, 2010). Wood’s claims were reversed by the state court, based on the premise that the counsel’s failure to investigate the evidence of wood’s mental deficiency was the strategic decision and an essential element of the counsel’s assistance in court (Wood v. Allen, 2010). The district court granted relief, stating that the counsel was ineffective and that there was no evidence to prove the strategic intention of the counsel to conceal the information about the state of Wood’s mental health. The U.S. Court of Appeal followed and reversed the decision of the district court, holding that Wood’s legal counsel was not ineffective (Wood v. Allen, 2010). The U.S. Court of Appeals for the Eleventh Circuit ruled that Wood’s attorneys acted reasonably and their decision to leave out the information about his health was a part of their defense strategy.

The Supreme Court had to resolve the two basic issues:

1. The Court had to decide whether it is enough for the petitioner to establish that the state-court factual determination that had led to the decision was unreasonable, or whether the petitioner also must rebut a presumption that the determination was correct and justified and to provide convincing evidence to support his position;
2. The Court had to decide whether the state court had been reasonable in determining that the counsel’s decision to leave out the information about Wood’s mental health had been strategic, conscious, and aimed to strengthen Wood’s position in defense (Wood v. Allen, 2010).

In summary, Justice Sonia Sotomayor and the Supreme Court Majority held that leaving out the evidence of Mr. Wood’s mental deficiencies was not an unreasonable determination of facts. Even though the term ‘unreasonable’ is difficult to define in legal terms, a court decision cannot be considered as unreasonable simply because the federal habeas court would have decided otherwise (Wood v. Allen, 2010). The U.S. Supreme Court found reliable evidence to prove that the court’s failure to determine and confirm Wood’s mental deficiency was not the result of mere oversight or neglect but the result of the deliberate counsel’s decision to focus on other defenses: all three Wood’s attorneys read Kirkland’s report about Wood’s mental health deficiencies and thus could not omit this information, unless with deliberate intent (Wood v. Allen, 2010).

The case is significant for two reasons. First, it directly relates to and supports the concept of habeas corpus in criminal justice: Wood actually filed a petition for a writ of habeas corpus and sought a relief from the death penalty. A writ of habeas corpus implies the need to bring the inmate to the court, to check whether his imprisonment is lawful or he should be released from custody (The Lectric Law Library, 2005). The case of Wood v. Allen (2010) proves the relevance and significance of the concept in legal practice and reveals the degree of responsibility with which courts treat inmates’ rights. Second, the case is important in the sense that it refers to the ambiguous provisions of §2254 (state custody and remedies in Federal courts). §2254 (d) provides a petitioner with the right for a writ of habeas corpus in case the decision was contrary to or involved an unreasonable application of Federal Law, or if the decision were based on an unreasonable determination of facts, taking into account the evidence presented in the state court proceeding (Cornell University Law School, 2010). The Supreme Court of the United States was very thorough in its judgments and objectively investigated all facts pertinent to the case. Because Wood’s counsel was aware of his mental state and did not present evidence during the state court proceeding, the petition for the unreasonable determination of facts was irrelevant and unjustified.

I agree with the court’s ruling, especially in part which relates to “unreasonable determination of facts”. I cannot but support Justice Sonia Sotomayor in that the meaning of ‘unreasonable’ in criminal justice is too vague. However, that all three attorneys read and were aware of the results of Kirkland’s report does not necessarily imply that they left out the information about his mental health state intentionally. The mistake could readily result of the attorneys’ disagreement, bearing in mind that the least experienced attorney was put in charge of the penalty phase of the conviction (Wood v. Allen, 2010). Nevertheless, the case of Wood v. Allen looks like another good reason for a person in custody to relieve the burden of the death penalty. Such relief would be reasonably unfair, taking into account the seriousness of Wood’s crime.

References

Cornell University Law School. (2010). §2254; State custody; remedies in Federal courts.

Cornell University Law School. Retrieved from http://www.law.cornell.edu/uscode/28/usc_sec_28_00002254—-000-.html

Lectric Law Library. (2005). Habeas Corpus. Lectric Law Library. Retrieved from http://www.lectlaw.com/def/h001.htm

Wood v. Allen. 558 U.S. (2010).