Woodford v. Visciotti

A jury convicted John Visciotti (defendant) of first-degree murder and related offenses and found that the murder was committed during a robbery. The jury then sentenced Visciotti to death. The California Supreme Court affirmed the conviction and death sentence. In state habeas proceedings, Visciotti argued that his counsel was ineffective. The California Supreme Court denied relief, assuming that trial counsel was ineffective during the penalty phase but concluding that this did not prejudice the jury during sentencing. Visciotti filed a federal habeas petition, and the federal district court found that counsel was ineffective during the penalty phase and granted relief only regarding Visciotti’s death sentence. The United States Court of Appeals for the Ninth Circuit affirmed, agreeing that counsel was ineffective. The Ninth Circuit found that the California Supreme Court’s rejection of Visciotti’s ineffective-assistance-of-counsel claim was both contrary to and an unreasonable application of clearly established federal law. The Ninth Circuit reasoned that the California Supreme Court’s decision was objectively unreasonable because (1) it neither accounted for all of the available mitigating evidence nor fully evaluated the prejudicial impact of some of Visciotti’s counsel’s actions and (2) the aggravating factors underlying Visciotti’s death sentence were not overwhelming. The United Sates Supreme Court granted certiorari.