Rompilla v. Beard 545 U.S. 374, 125 S. Ct. 2456, 162 L. Ed.2d 360 (2005)
Rompilla killed a guy and set
him on fire during a robbery.
The Trial Court found Rompilla
guilty of murder.
During the sentencing phase,
Rompilla's lawyers presented some mitigating evidence, but the jury found
that the aggravating factors of the crime outweighed the mitigating
factors and sentenced Rompilla to death. He appealed.
Rompilla was unhelpful in
preparing his own defense. Rompilla's counsel asked him if there was
anything in his background they could use as a mitigating factor, but he
told them that his background was unremarkable. The counsel didn't
The counsel had three
psychiatrists examine Rompilla, but they found him to be sane.
The Pennsylvania Supreme Court
The Pennsylvania Supreme
Court looked to Strickland v. Washington (466 U.S. 668 (1984)) and found that in order to obtain relief
due to ineffective assistance of counsel, a criminal defendant must show:
That counsel's performance
fell below an objective standard of reasonableness and,
That counsel's deficient
performance gives rise to a reasonable probability that, if counsel had
performed adequately, the result of the proceeding would have been
Rompilla asked for a writ of
habeus corpus in Federal Court.
Rompilla argued that he had
ineffective counsel during the sentencing phase because his counsel did
not uncover evidence that Rompilla had brain damage and an abusive
The only thing that the
counsel did was to have Rompilla's family members plead for mercy.
The Federal Trial Court found
for Rompilla. The prosecutor appealed.
The Federal Trial Court
found that Rompilla's counsel did not take reasonable efforts to uncover
Rompilla's mitigating factors.
For example, Rompilla's new
counsel looked into the records of his prior convictions and found
evidence showing that Rompilla had had some serious issues during
childhood. His original counsel failed look into Rompilla's record of
prior convictions despite knowing that the prosecution was going to use
it as an aggravating factor.
The Federal Appellate Court
reversed. Rompilla appealed.
The Federal Appellate Court
found that although the counsel did not unearth useful information in
Rompilla's school, medical, police, and prison records, their
investigation had gone far enough to give them reason to think that
further efforts would not be a wise use of their limited resources.
The US Supreme Court reversed
the Appellate Court and found that Rompilla did not have effective
The US Supreme Court found
that even when a defendant and his family members have suggested that no
mitigating evidence is available, his counsel is bound to make reasonable
efforts to obtain and review material that counsel knows the prosecution
will probably rely on as evidence of aggravation at the sentencing phase.
In this case, Rompilla's
counsel didn't look into all the records they should have reasonably
looked into. Therefore they did not provide Rompilla with as good a
defense as they could have and were therefore an infective counsel.
In a dissent it was argued
that Rompilla's counsel did an objectively reasonable job of preparing a
defense, and it isn't their fault that they didn't stumble upon some
information in an old case file.