Rompilla v. Beard
545 U.S. 374, 125 S. Ct. 2456, 162 L. Ed.2d 360 (2005)

  • Rompilla killed a guy and set him on fire during a robbery.
  • The Trial Court found Rompilla guilty of murder.
  • During the sentencing phase, Rompilla’s lawyers presented some mitigating evidence, but the jury found that the aggravating factors of the crime outweighed the mitigating factors and sentenced Rompilla to death. He appealed.
    • Rompilla was unhelpful in preparing his own defense. Rompilla’s counsel asked him if there was anything in his background they could use as a mitigating factor, but he told them that his background was unremarkable. The counsel didn’t investigate further.
      • The counsel had three psychiatrists examine Rompilla, but they found him to be sane.
  • The Pennsylvania Supreme Court affirmed.
    • The Pennsylvania Supreme Court looked to Strickland v. Washington (466 U.S. 668 (1984)) and found that in order to obtain relief due to ineffective assistance of counsel, a criminal defendant must show:
      • That counsel’s performance fell below an objective standard of reasonableness and,
      • That counsel’s deficient performance gives rise to a reasonable probability that, if counsel had performed adequately, the result of the proceeding would have been different.
  • Rompilla asked for a writ of habeus corpus in Federal Court.
    • Rompilla argued that he had ineffective counsel during the sentencing phase because his counsel did not uncover evidence that Rompilla had brain damage and an abusive childhood.
      • The only thing that the counsel did was to have Rompilla’s family members plead for mercy.
  • The Federal Trial Court found for Rompilla. The prosecutor appealed.
    • The Federal Trial Court found that Rompilla’s counsel did not take reasonable efforts to uncover Rompilla’s mitigating factors.
      • For example, Rompilla’s new counsel looked into the records of his prior convictions and found evidence showing that Rompilla had had some serious issues during childhood. His original counsel failed look into Rompilla’s record of prior convictions despite knowing that the prosecution was going to use it as an aggravating factor.
  • The Federal Appellate Court reversed. Rompilla appealed.
    • The Federal Appellate Court found that although the counsel did not unearth useful information in Rompilla’s school, medical, police, and prison records, their investigation had gone far enough to give them reason to think that further efforts would not be a wise use of their limited resources.
  • The US Supreme Court reversed the Appellate Court and found that Rompilla did not have effective counsel.
    • The US Supreme Court found that even when a defendant and his family members have suggested that no mitigating evidence is available, his counsel 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 sentencing phase.
      • In this case, Rompilla’s counsel didn’t look into all the records they should have reasonably looked into. Therefore they did not provide Rompilla with as good a defense as they could have and were therefore an infective counsel.
  • In a dissent it was argued that Rompilla’s counsel did an objectively reasonable job of preparing a defense, and it isn’t their fault that they didn’t stumble upon some information in an old case file.