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Keywords

defendantlawyerappealtrialrespondentjury trial
lawyerappealtrialrespondent

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U.S. v. Cronic, 466 U.S. 648, 104 S.Ct. 2039, 80 L.Ed.2d 657

Facts

Respondent and two associates were indicted for a mail fraud scheme involving over $9,400,000 in checks between banks in Florida and Oklahoma. Shortly before trial, the respondent's retained counsel withdrew, and a young lawyer with no jury trial experience was appointed with only 25 days to prepare. The government had spent over four years investigating the case. The respondent was convicted on 11 of 13 counts and sentenced to 25 years in prison. The Court of Appeals reversed the conviction, inferring a violation of the right to effective assistance of counsel based on the circumstances of the representation.

Respondent and two associates were indicted on mail fraud charges involving the transfer of over $9,400,000 in checks between banks in Tampa, Fla., and Norman, Okla., during a 4–month period in 1975. Shortly before the scheduled trial date, respondent's retained counsel withdrew. The court appointed a young lawyer with a real estate practice to represent respondent, but allowed him only 25 days for pretrial preparation, even though it had taken the Government over four and one-half years to investigate the case and it had reviewed thousands of documents during that investigation.

Issue

Did the circumstances surrounding the representation of the respondent justify an inference of ineffective assistance of counsel under the Sixth Amendment?

The question presented by the Government's petition for certiorari is whether the Court of Appeals has correctly interpreted the Sixth Amendment.

Rule

The right to effective assistance of counsel requires that the accused's case be subjected to meaningful adversarial testing, and a presumption of ineffectiveness can only arise from surrounding circumstances that make it unlikely that the defendant received effective assistance.

The right to the effective assistance of counsel is the right of the accused to require the prosecution's case to survive the crucible of meaningful adversarial testing.

Analysis

The Supreme Court found that the Court of Appeals erred by using an inferential approach to determine ineffective assistance of counsel without evidence of actual breakdown in the adversarial process. The five criteria considered by the Court of Appeals did not demonstrate that the appointed counsel failed to function meaningfully as the government's adversary. The Court emphasized that the accused must point to specific errors made by trial counsel to establish a claim of ineffective assistance.

While the Court of Appeals purported to apply a standard of reasonable competence, it did not indicate that there had been an actual breakdown of the adversarial process during a trial. Instead, it concluded that the circumstances surrounding the representation of respondent mandated an inference that counsel was unable to discharge his duties.

Conclusion

The Supreme Court reversed the Court of Appeals' decision and remanded the case for further proceedings, stating that the circumstances did not justify a presumption of ineffective assistance of counsel.

The judgment is reversed, and the case is remanded for further proceedings consistent with this opinion.

Who won?

The prevailing party was the United States, as the Supreme Court reversed the Court of Appeals' decision and upheld the conviction.

The Court of Appeals reversed the conviction because it concluded that respondent did not “have the Assistance of Counsel for his defence” that is guaranteed by the Sixth Amendment to the Constitution.

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