Rompilla v. Beard, 545 U.S. 374 (2005)

On January 14, 1988, James Scanlon was found murdered in his bar in Allentown, Pennsylvania, having been stabbed multiple times and set on fire. Ronald Rompilla was indicted for the murder, with the Commonwealth announcing its intention to seek the death penalty. During the trial, the jury convicted Rompilla on all counts. In the penalty phase, the prosecution presented evidence of three aggravating factors: the murder occurred during the commission of another felony, it involved torture, and Rompilla had a significant history of violent felony convictions. In contrast, the defense's mitigation evidence was limited to brief testimonies from family members expressing doubt about Rompilla's guilt and asking for mercy. Ultimately, the jury found the aggravating factors more compelling and sentenced Rompilla to death. Following his conviction, Rompilla sought post-conviction relief in Pennsylvania, claiming ineffective assistance of counsel due to the failure to present significant mitigating evidence regarding his troubled childhood, mental health issues, and alcoholism. The post-conviction court ruled that trial counsel had conducted a sufficient investigation, and the Pennsylvania Supreme Court affirmed this decision. Subsequently, Rompilla filed a petition for a writ of habeas corpus in federal court, arguing that his representation was inadequate. The District Court found that the Pennsylvania Supreme Court had unreasonably applied the standard set forth in Strickland v. Washington regarding ineffective assistance of counsel, particularly in the context of the penalty phase of his trial. The case ultimately reached the U.S. Supreme Court, which addressed the standard of reasonable competence required of defense counsel under the Sixth Amendment. The Court held that even if a defendant's family and the defendant himself suggest that no mitigating evidence exists, the defense attorney is still obligated to make reasonable efforts to obtain and review materials that could be relevant to the sentencing phase, particularly evidence that the prosecution might use to establish aggravating factors.

Whether a capital defendant's counsel is required to make reasonable efforts to obtain and review evidence that the prosecution will likely use in aggravation, even when the defendant and their family suggest that no mitigating evidence is available.

The judgment is reversed.