Schriro v. Landrigan, 550 U.S. 465 (2007)
Primary Holding
The decision to grant an evidentiary hearing in federal habeas relief cases rests within the discretion of the district court, and such a hearing is not warranted if the applicant cannot make out a colorable claim of ineffective assistance of counsel.
In the case of Schriro v. Landrigan, the Supreme Court decided that a federal court can choose whether or not to hold a hearing when someone claims their lawyer didn’t do a good job in their trial. This matters because it sets a standard for when a person can challenge their conviction based on claims of ineffective legal help. For consumers, this case is important if they ever find themselves in a situation where they believe their lawyer failed to represent them properly, as it clarifies that they must show strong reasons for a hearing to be granted.
AI-generated plain-language summary to help you understand this case
In Schriro v. Landrigan, Jeffrey Timothy Landrigan was convicted in Arizona for theft, second-degree burglary, and felony murder, stemming from the murder of Chester Dean Dyer during the commission of a burglary. Prior to this conviction, Landrigan had a criminal history that included a conviction for second-degree murder in Oklahoma in 1982 and an assault on another inmate while in custody. During his sentencing in Arizona, Landrigan's attorney sought to present mitigating evidence through testimony from Landrigan's ex-wife and mother; however, both women declined to testify at Landrigan's request. The trial judge directly questioned Landrigan about his wishes, and he confirmed that he did not want any mitigating circumstances presented, asserting that there were none he deemed relevant. The procedural history of the case involved Landrigan seeking federal habeas relief after his conviction. The District Court reviewed the state-court record and additional evidence but ultimately determined that Landrigan could not establish a colorable claim of ineffective assistance of counsel, thus denying him an evidentiary hearing. Landrigan appealed this decision, and the Court of Appeals for the Ninth Circuit held that the District Court had abused its discretion by not granting the hearing. The case was then brought before the Supreme Court of the United States on a writ of certiorari. The relevant background context includes the legal standards for federal habeas relief under 28 U.S.C. § 2254(e)(2), which restricts evidentiary hearings in certain circumstances. The Supreme Court's decision focused on the discretion of the district court in granting such hearings and the implications of a defendant's choices regarding the presentation of mitigating evidence during sentencing. The case highlights the complexities surrounding ineffective assistance of counsel claims and the defendant's autonomy in making strategic decisions during trial proceedings.
Whether a federal district court's decision to deny an evidentiary hearing on a claim of ineffective assistance of counsel, based on the determination that the applicant could not make out a colorable claim, constitutes an abuse of discretion under 28 U.S.C. § 2254(e)(2).
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- January 9, 2007
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Thomas
- Damages Awarded
- N/A
- Data Quality
- high
Rompilla v. Beard, 545 U.S. 374 (2005)
Consumer LostEven when a capital defendant's family members and the defendant himself suggest that no mitigating evidence is available, defense counsel is required by the Sixth Amendment to make reasonable efforts to obtain and review material that the prosecution will likely use as evidence of aggravation during the sentencing phase of trial.
Fry v. Pliler, 551 U.S. 112 (2007)
Mixed OutcomeA federal habeas court must assess the prejudicial impact of constitutional error in a state-court criminal trial under the "substantial and injurious effect" standard established in Brecht v. Abrahamson, even when the state appellate court failed to recognize the error and did not review it for harmlessness.
Roper v. Weaver, 550 U.S. 598 (2007)
Consumer LostThe Supreme Court held that the Court of Appeals did not exceed its authority under the Antiterrorism and Effective Death Penalty Act (AEDPA) when it set aside a capital sentence based on the prosecutor's "unfairly inflammatory" closing statement, emphasizing the need for a more stringent standard of review in such cases.
Nunez v. United States, 554 U.S. 911 (2008)
Mixed OutcomeThe Supreme Court vacated the judgment of the Court of Appeals and remanded the case for further consideration, indicating that the lower court may have misconstrued the scope of the petitioner's collateral-review waiver.