Wednesday, April 19, 2006

Ineffective assistance and the applicability of AEDPA

In Rolan v. Vaughn, the Third Circuit addressed numerous issues relating to habeas relief. The petitioner in Rolan had petitioned the PA state courts for post-conviction relief, based upon ineffective assistance of counsel, claiming that his attorney had failed to investigate possible defenses. The PA Superior Court ultimately denied such relief, simply ruling that any such deficient performance of counsel could not have prejudiced the defendant. On habeas, the federal district court did not apply the deference to the state court’s factual findings under AEDPA and granted relief, stating that counsel’s failure to investigate was, in fact, ineffective and prejudicial.

On appeal, the Third Circuit first addressed whether AEDPA should have applied. It first stated that AEDPA only applies if the PA Court rejected Rolan’s claim on the merits. The Court determined that the state court did adjudicate the claim on the merits, despite the state court’s decision to dispose of the case for lack of any potential prejudice, rather than on a factual determination as to whether or not Rolan received ineffective assistance of counsel. Thus, AEDPA’s deferential standard of review applied.

Therefore, the district court should have deferred to the state court’s findings of fact, unless a review of the record revealed that the state court’s findings were unreasonable. The Third Circuit then undertook this reasonableness inquiry. The Court determined that the findings of fact (regarding a particular witness’ willingness to testify for the defendant) made by the district court were unreasonable. Accordingly, after reviewing the record, the Court agreed with the district court’s ruling that Rolan had received ineffective assistance of counsel, because Rolan’s attorney failed to properly investigate possible defenses before trial. Because this ineffective assistance did prejudice Rolan’s trial, the Court affirmed the district court’s grant of habeas relief.

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