Gary Eldon Alvord v. Louie L. Wainwright
United States Supreme Court
469 U.S. 956 (1984)
- Written by Monica Rottermann , JD
Facts
Gary Eldon Alvord (plaintiff) filed a federal habeas petition against Louie L. Wainwright (defendant), arguing that his attorney was ineffective in failing to investigate or pursue an insanity defense. Alvord had a long history of mental illness beginning with a hospitalization at the age of 13. In 1967, Alvord was charged with rape and murder in Michigan and spent two years institutionalized until he was found competent to stand trial. Alvord was found not guilty by reason of insanity and confined to a mental institute. Alvord later escaped the institute and committed three murders in Florida. A part-time public defender was appointed to represent Alvord. The attorney was informed about the prior insanity plea by the prosecutor. Alvord was supposed to be evaluated by two psychiatrists, but Alvord refused to speak with them without his attorney present and the attorney did not attend the meetings. The psychiatrist that previously evaluated Alvord in Michigan met with Alvord and stated that Alvord was competent. After that meeting, the two psychiatrists were able to meet with Alvord and one found Alvord competent and the other stated no opinion. The trial court determined Alvord was competent. Alvord’s attorney did not review Alvord’s medical records, did not order additional evaluations, did not inform the trial court of Alvord’s prior insanity plea, and spent minimal time meeting with Alvord to discuss the case. The attorney only met with Alvord for 15 minutes while Alvord was on suicide watch in his cell and thereafter only at court hearings. At Alvord’s request, the attorney did not present an insanity defense, even though Alvord was entitled to a presumption of insanity based on the prior insanity finding in Michigan. The attorney presented only a weak alibi defense at the request of Alvord. Alvord was found guilty and sentenced to death. The district court denied Alvord’s habeas petition, finding that the attorney acted reasonably in failing to present the insanity defense because Alvord did not cooperate. The Eleventh Circuit Court of Appeals affirmed, stating that an attorney is required to abide by a client’s requests. Alvord sought review with the United States Supreme Court.
Rule of Law
Issue
Holding and Reasoning ()
Dissent (Marshall, J.)
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