Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

defendantattorneyappealtrialjury trial
defendantappealtrialmotion

Related Cases

Zeidwig v. Ward, 548 So.2d 209, 58 USLW 2161, 14 Fla. L. Weekly 392
View Case »
Reed v. Superior Court, 92 Cal.App.4th 448, 111 Cal.Rptr.2d 842, 01 Cal. Daily Op. Serv. 8278, 2001 Daily Journal D.A.R. 10,183
View Case »
McCullough v. Waterside Associates, 102 Conn.App. 23, 925 A.2d 352
View Case »
Adell v. Sommers, Schwartz, Silver and Schwartz, P.C., 170 Mich.App. 196, 428 N.W.2d 26
View Case »
Smith v. Spisak, 558 U.S. 139, 130 S.Ct. 676, 175 L.Ed.2d 595, 78 USLW 4031, 10 Cal. Daily Op. Serv. 392, 22 Fla. L. Weekly Fed. S 35
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Bobby v. Van Hook, 558 U.S. 4, 130 S.Ct. 13, 175 L.Ed.2d 255, 78 USLW 3265, 78 USLW 3267, 78 USLW 4001, 09 Cal. Daily Op. Serv. 13,564, 2009 Daily Journal D.A.R. 15,833, 22 Fla. L. Weekly Fed. S 3

Facts

On February 18, 1985, Robert Van Hook went to a bar in Cincinnati, where he met David Self. After spending time together, they went to Self's apartment, where Van Hook attacked and killed him, subsequently mutilating the body. Van Hook was indicted for aggravated murder and robbery, waived his right to a jury trial, and was found guilty by a three-judge panel. During sentencing, the defense presented several mitigation witnesses, but the court ultimately imposed the death penalty. Van Hook's subsequent appeals and postconviction relief efforts were unsuccessful, leading to his federal habeas petition.

On February 18, 1985, Van Hook went to a Cincinnati bar that catered to homosexual men, hoping to find someone to rob. He approached David Self, and after the two spent several hours drinking together they left for Self's apartment. There Van Hook “lured Self into a vulnerable position” and attacked him, first strangling him until he was unconscious, then killing him with a kitchen knife and mutilating his body.

Issue

Did the Court of Appeals err in granting habeas relief on the grounds of ineffective assistance of counsel during the sentencing phase of Van Hook's capital trial?

Did the Court of Appeals err in granting habeas relief on the grounds of ineffective assistance of counsel during the sentencing phase of Van Hook's capital trial?

Rule

The Sixth Amendment guarantees criminal defendants the right to effective assistance of counsel, which requires representation that does not fall below an objective standard of reasonableness in light of prevailing professional norms.

The Sixth Amendment entitles criminal defendants to the “ ‘effective assistance of counsel’ ”—that is, representation that does not fall “below an objective standard of reasonableness” in light of “prevailing professional norms.”

Analysis

The Supreme Court found that the Court of Appeals incorrectly applied the ABA Guidelines from 2003 to evaluate the performance of Van Hook's counsel, which were not in effect at the time of his trial. The Court emphasized that the attorneys' actions were consistent with the standards that prevailed during the 1980s, and their investigation into mitigating evidence was adequate. The Court concluded that even if the attorneys had performed deficiently, Van Hook did not suffer any prejudice as the evidence presented at trial was sufficient to support the death penalty.

The Sixth Circuit ignored this limiting principle, relying on ABA guidelines announced 18 years after Van Hook went to trial.

Conclusion

The Supreme Court reversed the Court of Appeals' decision and remanded the case for further proceedings, affirming that Van Hook's counsel met the constitutional minimum of competence.

The petition for certiorari and the motion for leave to proceed in forma pauperis are granted. The judgment of the Court of Appeals is reversed, and the case is remanded for further proceedings consistent with this opinion.

Who won?

The State of Ohio prevailed in the case because the Supreme Court found that Van Hook's counsel did not provide ineffective assistance during the sentencing phase.

The Supreme Court held that: 1 it was inappropriate for the Court of Appeals to rely on the American Bar Association Guidelines for the Appointment and Performance of Defense Counsel in Death Penalty Cases, which were announced 18 years after the petitioner's trial, and 2 counsel did not perform deficiently, as element of ineffective assistance of counsel, in investigating penalty-phase mitigation evidence regarding petitioner's background.

You must be