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attorneyappealtrialtestimonyparolecross-examinationobjectionwitness testimonylife imprisonment
defendantattorneytrial

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Haynes v. Cain, 298 F.3d 375

Facts

In October 1993, Brandon Haynes was accused of kidnapping, raping, and murdering Fang Yang at the LSU Medical Center. Evidence against him included video surveillance, eyewitness testimony, and DNA analysis. During the trial, Haynes' attorneys conceded that he was guilty of second-degree murder to avoid the death penalty, despite Haynes' objections. The jury convicted him of first-degree murder, and he was sentenced to life imprisonment without parole.

In October of 1993, Haynes was employed on a construction project at the Louisiana State University Biomedical Center in Shreveport, Louisiana. Around midnight on October 27, 1993, Haynes entered the LSU Medical Center, which was located next to the construction site. While walking through the Medical Center, Haynes encountered a female graduate student, Fang Yang, who was conducting research in one of the Medical Center's laboratories. Haynes forcibly took Yang to the roof of the building where he proceeded to rape and rob her.

Issue

Did the defense counsel's concession of guilt to a lesser charge constitute ineffective assistance of counsel under the Sixth Amendment?

The court held that: (1) District court should not have reviewed de novo state court's decision that defendant's counsel had not provided ineffective assistance; (2) opening-statement concession by defendant's attorney that defendant was guilty of second-degree murder was strategic attempt to avoid death penalty, not failure to subject prosecution's case to meaningful adversarial testing, and thus did not raise presumption of prejudice; and (3) failure to obtain defendant's consent before conceding to second-degree murder did not prejudice defendant.

Rule

The court applied the standards set forth in Strickland v. Washington, which requires showing that counsel's performance was deficient and that the deficiency prejudiced the defense. The court also considered the Cronic standard, which applies when counsel entirely fails to subject the prosecution's case to meaningful adversarial testing.

We now must determine whether the Louisiana state court's application of Strickland v. Washington, 466 U.S. 668, 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984) in this case was contrary to, or involved an unreasonable application of, clearly established federal law.

Analysis

The court found that Haynes' attorneys did not entirely fail to challenge the prosecution's case; rather, they made a strategic decision to concede guilt on the lesser charge of second-degree murder to avoid a death sentence. The attorneys actively engaged in cross-examination and attempted to create reasonable doubt regarding Haynes' intent to kill, which indicated that they were providing meaningful representation.

In sum, this is not a situation in which Haynes' attorneys abandoned their client. Instead, they continued to represent him throughout the course of the trial, adopting a strategy which in their judgment accorded Haynes the best opportunity for a favorable outcome.

Conclusion

The Court of Appeals reversed the district court's grant of habeas relief, concluding that the state court's application of Strickland was not unreasonable and that Haynes was not prejudiced by his counsel's strategic decisions.

Thus, we hold that the Louisiana state court properly identified Strickland as the correct governing legal principle under which to evaluate Haynes' ineffective assistance of counsel claim.

Who won?

The Warden prevailed in the case because the Court of Appeals determined that the state court's decision was not contrary to federal law and that Haynes' counsel's performance did not constitute ineffective assistance.

The Warden maintains that the district court and the panel majority erred in granting federal habeas relief because the state habeas court's decision was not contrary to, or an unreasonable application of, clearly established federal law.

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