WASHINGTON—The Supreme Court overturned a Pennsylvania man's death sentence Monday, saying his court-appointed lawyers failed to adequately investigate evidence that could have persuaded a jury to spare his life.
The 5-4 ruling gives teeth to a prior decision that heightened standards for defense lawyers in capital cases. And it provides important context for a federal law aimed at limiting death row appeals.
The ruling will have the most immediate impact for Ronald Rompilla, who beat, stabbed and set afire an Allentown, Pa., tavern owner in 1988. He'll leave Pennsylvania's death row and return only if prosecutors decide to seek a new hearing to have him executed.
Chief federal defender Maureen K. Rowley, whose office represented Rompilla in the high court, said if Rompilla had lost, he could have become the first prisoner involuntarily executed in Pennsylvania in nearly 50 years.
"The Supreme Court is clearly stating that a certain level of practice, diligence and reasonable investigation is required by criminal defense lawyers at the trial stage," Rowley said. "They're setting the bar."
The quality of trial counsel has been a persistent issue in Pennsylvania capital appeals. At least three dozen cases, including about 20 from Philadelphia, have been given new sentencing hearings or new trials because defense lawyers were deemed ineffective. Though Pennsylvania carries out few executions, the state has the nation's fourth-largest death row, with 220 inmates awaiting execution.
Rowley said the quality of trial representation has been a serious issue in Pennsylvania because of a lack of funding in capital cases for a meaningful investigation of an indigent defendant's background. That information, in turn, could be used to convince a jury that there was sufficient mitigating evidence to warrant a sentence of life in prison rather than death.
Monday's ruling follows the justices' long-established course toward significant death-penalty reform. Last week, the court made it easier for defendants to raise claims of racial bias in jury selection. Earlier in this term, the justices declared juvenile executions unconstitutional.
In Rompilla's case, the justices returned to a subject they've addressed several times before: How much must lawyers do to defend their clients in capital cases? The court has said that lawyers must investigate their clients' backgrounds for evidence—such as mental retardation, violently abusive childhoods or substance abuse problems—that juries can use as "mitigating" evidence to decide whether a death sentence is inappropriate.
The justices have blasted lawyers in cases in which they did almost nothing to investigate their clients' backgrounds. But the ruling in Rompilla's case indicates how broadly the justices want their standard applied.
The justices said Rompilla's lawyers, who conducted a background investigation but ignored a court file with evidence of serious dysfunction in their client's past, failed those standards. The majority said the lawyers had an obligation, especially since they knew prosecutors intended to use information from the same file against Rompilla, to review the records.
"If the defense lawyers had looked in the file on Rompilla's prior conviction," Justice David Souter wrote for the court, "it is uncontested they would have found a range of mitigation leads that no other source had opened up."
Souter, joined by justices John Paul Stevens, Sandra Day O'Connor, Ruth Bader Ginsburg and Stephen Breyer, also chided the Third Circuit Court of Appeals for its interpretation of a federal law that aims to limit death row appeals.
The law says federal courts can overturn capital sentences only when they determine that state courts have "unreasonably" applied federal law.
In Rompilla's case, "it flouts prudence to deny that a defense lawyer should try to look at a file he knows the prosecution will cull for aggravating evidence," Souter wrote. "No reasonable lawyer would forgo examination of the file thinking he could do as well by asking the defendant or family relations what they recalled."
Justice Anthony Kennedy dissented, joined by Chief Justice William Rehnquist and justices Antonin Scalia and Clarence Thomas. Kennedy said Rompilla's lawyers couldn't be expected to look in every court file for mitigating evidence, and there was no reason to look in the one the court faulted them for missing.
"Under any standard of review, the investigation performed by Rompilla's counsel in preparation for sentencing was not only adequate but also conscientious," Kennedy wrote. "Today's decision is wrong under any standard."
(c) 2005, Knight Ridder/Tribune Information Services.
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