Schriro v. Landrigan

Jeffrey Landrigan (defendant) was serving a prison sentence for second-degree murder. About seven years after his conviction, Landrigan escaped from prison and committed another murder. He was convicted of felony murder for killing a person during a burglary. During the sentencing phase of his trial, Landrigan prevented his counsel from presenting mitigating evidence. His counsel intended that Landrigan’s ex-wife and his birth mother testify to the fact that Landrigan had abused drugs and alcohol and that Landrigan’s birth mother used drugs and alcohol both while she was pregnant with Landrigan and after his birth. Landrigan instructed the two women not to testify, so they refused. The trial judge canvassed Landrigan as to his decision to forgo the presentation of mitigating evidence. Landrigan was adamant that he did not want mitigating evidence presented. Landrigan even interrupted when his attorney tried to offer mitigating evidence. He seemed intent on receiving the death penalty. The judge found two statutory aggravating circumstances and two nonstatutory mitigating circumstances. Ultimately, the judge sentenced Landrigan to death. After the Arizona Supreme Court affirmed his sentence, Landrigan eventually filed a petition for ineffective assistance of counsel, alleging that his counsel failed to investigate additional grounds for mitigating evidence, such as the biological component of his violent behavior. The claim was rejected. The Arizona Supreme Court declined to review the decision. Landrigan then filed a federal habeas corpus claim, which was denied by the district court. A panel of the court of appeals affirmed the denial. After a rehearing en banc, the court reversed the panel judgment and ordered an evidentiary hearing on counsel’s lack of investigation. The United States Supreme Court granted certiorari.