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Keywords

defendanttrialpleapublic defenderguilty plea
defendanttrialpleapublic defenderguilty plea

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Florida v. Nixon, 543 U.S. 175, 125 S.Ct. 551, 160 L.Ed.2d 565, 73 USLW 4047, 04 Cal. Daily Op. Serv. 10,880, 2004 Daily Journal D.A.R. 14,745, 18 Fla. L. Weekly Fed. S 33

Facts

Joe Elton Nixon was arrested for the brutal murder of Jeanne Bickner, whose body was discovered charred and tied to a tree. Nixon confessed to the crime in detail, leading to his indictment for first-degree murder, kidnapping, robbery, and arson. His assigned public defender, Michael Corin, determined that Nixon's guilt was not subject to reasonable dispute and decided to concede guilt during the trial to focus on mitigating factors in the penalty phase. Nixon was largely unresponsive to Corin's strategy discussions and engaged in disruptive behavior during the trial.

Nixon was indicted in Leon County, Florida, for first-degree murder, kidnaping, robbery, and arson. Assistant public defender Michael Corin, assigned to represent Nixon, filed a plea of not guilty, and deposed all of the State's potential witnesses. Corin concluded, given the strength of the evidence, that Nixon's guilt was not 'subject to any reasonable dispute.'

Issue

Whether defense counsel's failure to obtain the defendant's express consent to a strategy of conceding guilt in a capital trial automatically renders counsel's performance deficient.

Whether counsel's failure to obtain the defendant's express consent to a strategy of conceding guilt in a capital trial automatically renders counsel's performance deficient.

Rule

The effectiveness of counsel should be evaluated under the Strickland standard, which assesses whether counsel's representation fell below an objective standard of reasonableness, rather than the Cronic standard, which applies in cases where counsel has entirely failed to function as the client's advocate.

Counsel's effectiveness should not be evaluated under the Cronic standard, but under the standard prescribed in Strickland v. Washington, 466 U.S. 668, 688, 104 S.Ct. 2052, 80 L.Ed.2d 674: Did counsel's representation 'f [a]ll below an objective standard of reasonableness?'

Analysis

The U.S. Supreme Court found that the Florida Supreme Court erred in requiring Nixon's explicit consent for the concession strategy, equating it to a guilty plea. The Court emphasized that despite the concession, Nixon retained his rights in a criminal trial, and the prosecution was still required to present evidence of guilt. Corin's strategy was deemed reasonable given the overwhelming evidence against Nixon, and his failure to obtain express consent did not automatically indicate ineffective assistance.

The Florida Supreme Court erred in requiring Nixon's affirmative, explicit acceptance of Corin's strategy because it mistakenly deemed Corin's statements to the jury the functional equivalent of a guilty plea.

Conclusion

The U.S. Supreme Court reversed the Florida Supreme Court's judgment, holding that the failure to obtain express consent to a concession of guilt does not automatically render counsel's performance deficient.

Held: Counsel's failure to obtain the defendant's express consent to a strategy of conceding guilt in a capital trial does not automatically render counsel's performance deficient.

Who won?

The U.S. Supreme Court prevailed, ruling that the Florida Supreme Court applied the wrong standard in evaluating the effectiveness of counsel.

The Florida Supreme Court's erroneous equation of Corin's concession strategy to a guilty plea led it to apply the wrong standard in determining whether counsel's performance ranked as ineffective assistance.

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