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Keywords

defendantattorneytrialtestimonyforensic evidenceexpert witnesswitness testimony
defendantattorneyappealtrialmotionexpert witness

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Hinton v. Alabama, 571 U.S. 263, 134 S.Ct. 1081, 188 L.Ed.2d 1, 82 USLW 3491, 82 USLW 4091, 14 Cal. Daily Op. Serv. 1863, 2014 Daily Journal D.A.R. 2171, 24 Fla. L. Weekly Fed. S 541

Facts

In February 1985, a restaurant manager in Birmingham was shot during a robbery, followed by another similar murder in July. Hinton was linked to the crimes through eyewitness testimony and forensic evidence from a revolver found in his home. At trial, the State's case relied heavily on expert testimony that the bullets from the crime scenes were fired from Hinton's revolver. Hinton maintained his innocence and presented an alibi, but was ultimately convicted and sentenced to death.

In February 1985, a restaurant manager in Birmingham was shot to death in the course of an after-hours robbery of his restaurant. A second manager was murdered during a very similar robbery of another restaurant in July. Then, later in July, a restaurant manager named Smotherman survived another similar robbery-shooting.

Issue

Did Hinton's trial attorney provide ineffective assistance of counsel by failing to seek additional funding for a qualified expert witness, thereby violating Hinton's Sixth Amendment rights?

Did Hinton's trial attorney provide ineffective assistance of counsel by failing to seek additional funding for a qualified expert witness, thereby violating Hinton's Sixth Amendment rights?

Rule

Under Strickland v. Washington, a criminal defendant's right to counsel is violated if the attorney's performance falls below an objective standard of reasonableness and if there is a reasonable probability that the result of the trial would have been different absent the deficient act or omission.

In Strickland v. Washington, 466 U.S. 668, 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984), we held that a criminal defendant's Sixth Amendment right to counsel is violated if his trial attorney's performance falls below an objective standard of reasonableness and if there is a reasonable probability that the result of the trial would have been different absent the deficient act or omission.

Analysis

The court found that Hinton's attorney's failure to request additional funds for a competent expert witness constituted deficient performance, as it was based on a mistaken belief about funding limits. This failure was not a strategic choice but rather a misunderstanding of the resources available under Alabama law. The court emphasized that effective rebuttal of the prosecution's expert testimony was crucial, and the attorney's ignorance of the law led to the hiring of an inadequate expert.

Under Strickland, we first determine whether counsel's representation ‘fell below an objective standard of reasonableness.’ Then we ask whether ‘there is a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different.’

Conclusion

The Alabama Supreme Court reversed the lower court's judgment and remanded the case for reconsideration of whether Hinton's attorney's deficient performance was prejudicial, thereby entitling Hinton to a new trial.

The petition for certiorari and Hinton's motion for leave to proceed in forma pauperis are granted, the judgment of the Court of Criminal Appeals of Alabama is vacated, and the case is remanded for further proceedings not inconsistent with this opinion.

Who won?

Anthony Ray Hinton prevailed in the case as the Alabama Supreme Court reversed the lower court's decision, recognizing the ineffective assistance of his trial counsel.

The Supreme Court was thus focused on Payne's own qualifications, rather than on whether a better expert—one who could have been hired had the attorney learned that there was no funding cap and requested additional funds—would have made a more compelling case for Hinton.

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