First Decision by Justice Sotomayor Upholds Death Sentence
In a 7 to 2 decision announced today, the United States Supreme Court has rejected an Alabama murderer’s claim that his three state-appointed lawyers failed to adequately represent him during his sentencing hearing. The defendant in the case of Wood v. Allen argued that his death sentence was invalid because his defense attorneys did not thoroughly investigate and produce evidence of his borderline range of intellectual functioning.
At the invitation of the Solicitor General of Alabama, the California-based Criminal Justice Legal Foundation joined the case to introduce a scholarly amicus curiae (friend of the court) brief. The Foundation argued that Wood’s claims and all the related evidence were properly reviewed by the Alabama courts, and federal law requires that a state court decision should stand unless it is unreasonable. A federal court’s simple disagreement on a debatable point is not sufficient to overturn a final judgment.
Justice Sonia Sotomayor wrote the majority opinion, holding, “It suffices to say, however, that a state court factual determination is not unreasonable merely because the federal habeas court would have reached a different conclusion in the first instance.” This is Justice Sotomayor’s first full opinion in a capital case.
“Today’s decision implements the intent of Congress to reduce repeated litigation of close questions and the delay that results from such repetition,” said Kent Scheidegger, the Foundation’s Legal Director. “In cases such as this, with no genuine question of guilt, one fair review of the facts and the law should be enough.”
When Justice Sotomayor was nominated for the Supreme Court, CJLF reviewed her decisions under the 1996 act of Congress that limited federal court review of state convictions. The Foundation found that she had generally followed the law as written and intended, unlike the evasions of many other federal judges. However, none of the cases were capital, leaving some observers to wonder if she would rule differently in capital cases. Today’s opinion is consistent in its approach with her earlier opinions on the Court of Appeals and District Court.
The defendant, Holly Wood, was convicted on strong evidence of the shotgun murder of his girlfriend in September 1993. At the time of the murder, Wood was on parole after serving 5 years of a 15-year prison sentence for shooting another former girlfriend in 1985.
Evidence introduced at his trial indicates that shortly after his release on parole, Wood moved in with Ruby Gosha, his new girlfriend and the mother of his child. Within three months, the relationship had soured and, when Wood learned that Gosha was dating another man, he attacked her with a knife. While Gosha managed to escape, she lost the use of two fingers when her wrist was slit during the attack.
The following month, Wood and a cousin went to Gosha’s house. When her mother answered the door and demanded that he leave, Wood told Ruby, “I will get you some day.”
Later that night, Wood snuck into the Gosha home, placed a shotgun to the head of a sleeping Ruby Gosha, and pulled the trigger. As his cousin drove Wood away from the murder scene, Wood threw the shotgun shells out of the window and later buried the gun behind his father’s house. During the getaway, he told his cousin he had “blowed her (Gosha’s) brains out, and all she did was wiggle.”
For his trial, Wood was represented by three attorneys. The lead attorney was a former Assistant Attorney General and Deputy District Attorney who, in private practice, had represented “probably a thousand criminal defendants,” including three death penalty cases. The second attorney had represented defendants in over 50 felony trials over his 30-year career. The third attorney was a recent law school graduate assisting in his first jury trial.
Faced with overwhelming evidence of guilt, the defense team sought a psychiatric evaluation of Wood. The evaluation revealed that Wood had a low IQ, but that he suffered no mental impairment that prevented him from understanding that his criminal behavior was wrong, and he had a “normal thought process.” Wood also told the doctor that he had trouble controlling his anger and had wanted to injure others in the past. Recognizing that the evaluation and Wood’s own statements about being prone to violent behavior might harm their defense, his lead attorney asked the court to suppress it and all other psychiatric and psychological evidence from the trial and sentencing hearing.
Following Wood’s conviction for capital murder, his defense counsel presented testimony and other evidence to discourage a death sentence at the penalty hearing. This included evidence of his difficult childhood, his mother’s death when he was 10, and his only brother’s death the next year. In spite of this, the jury recommended a death sentence.
After his conviction and sentence were upheld on direct appeal, Wood challenged his sentence on state postconviction review. Three separate evidentiary hearings were held between 2000 and 2003 to consider Wood’s claim that he was mentally retarded and that his defense counsel failed to adequately represent him at the penalty hearing. The conclusion of this review was that neither claim was supported by the evidence. The lawyers’ decision not to proceed further with mental evidence was a strategic decision which took into account the significant damaging evidence that such a defense would allow in. On federal habeas corpus, the district court agreed that Wood was not retarded but announced that his defense counsel was ineffective for failing to further investigate and introduce evidence of his intellectual functioning. On appeal, the Eleventh Circuit Court of Appeals reversed this holding.
When the Supreme Court agreed to review Wood’s appeal of that ruling, the American Civil Liberties Union and the National Association of Criminal Defense Attorneys joined his appointed attorney to encourage a decision to overturn his death sentence. The defense and its supporters claim that Wood’s defense counsel failed to thoroughly investigate his mental condition and that the least experienced attorney in Wood’s legal team had chosen not to present the evidence of his low IQ to the sentencing jury.
The Supreme Court agreed with the Eleventh Circuit Court of Appeals that the state court’s finding of fact regarding the lawyers’ strategic decision was reasonable based on the evidence before the court. The Supreme Court declined to reconsider the Eleventh Circuit’s further holding that the trial attorneys were not ineffective, because Wood’s current lawyer had not included that question among those he asked the Court to review.