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Keywords

torttrialfelony
tortdefendantlawyertrialtestimonywillfelony

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Rompilla v. Beard, 545 U.S. 374, 125 S.Ct. 2456, 162 L.Ed.2d 360, 73 USLW 4522, 05 Cal. Daily Op. Serv. 5306, 2005 Daily Journal D.A.R. 7244, 18 Fla. L. Weekly Fed. S 419, 31 A.L.R. Fed. 2d 595

Facts

Ronald Rompilla was convicted of murder and sentenced to death after the jury found several aggravating factors, including that the murder was committed during a felony and by torture. During the penalty phase, his trial counsel failed to investigate significant mitigating evidence regarding Rompilla's troubled childhood, mental health issues, and alcoholism. The state courts initially found that trial counsel had sufficiently investigated mitigation possibilities, but Rompilla later raised claims of inadequate representation in a federal habeas petition.

Petitioner Rompilla was convicted of murder and other crimes. During the penalty phase, the jury found the aggravating factors that the murder was committed during a felony, that it was committed by torture, and that Rompilla had a significant history of felony convictions indicating the use or threat of violence.

Issue

Did the defense counsel's failure to examine the file on Rompilla's prior conviction for rape and assault constitute ineffective assistance of counsel under the Sixth Amendment?

Did the defense counsel's failure to examine the file on Rompilla's prior conviction for rape and assault constitute ineffective assistance of counsel under the Sixth Amendment?

Rule

Defense counsel is required to conduct a reasonable investigation into mitigating evidence, especially when the prosecution intends to use prior convictions as aggravating evidence during the sentencing phase.

Even when a capital defendant and his family members have suggested that no mitigating evidence is available, his lawyer 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 trial's sentencing phase.

Analysis

The Supreme Court found that Rompilla's defense counsel fell below the standard of reasonable performance by not examining the readily available court file on his prior conviction. The court emphasized that counsel's failure to investigate the prosecution's evidence compromised their ability to respond effectively during the sentencing phase. The court also noted that the prior conviction file contained critical information that could have significantly influenced the jury's perception of Rompilla's culpability.

The lawyers were deficient in failing to examine the court file on Rompilla's prior rape and assault conviction. They knew that the Commonwealth intended to seek the death penalty by proving that Rompilla had a significant history of felony convictions indicating the use or threat of violence, that it would attempt to establish this history by proving the prior conviction, and that it would emphasize his violent character by introducing a transcript of the rape victim's trial testimony.

Conclusion

The Supreme Court reversed the Third Circuit's decision, holding that Rompilla was entitled to habeas relief due to ineffective assistance of counsel.

The Supreme Court, Justice Souter, held that: defense counsel's failure to examine file on defendant's prior conviction for rape and assault at sentencing phase of capital murder trial fell below the level of reasonable performance, and such failure was prejudicial to defendant, warranting habeas relief on grounds of ineffective assistance of counsel.

Who won?

Rompilla prevailed in the case because the Supreme Court determined that his defense counsel's failure to investigate mitigating evidence constituted ineffective assistance, which warranted habeas relief.

Rompilla prevailed in the case because the Supreme Court determined that his defense counsel's failure to investigate mitigating evidence constituted ineffective assistance, which warranted habeas relief.

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