In Williams v. Allen, No. 07-11393 (Sept. 17, 2008), the Court (Birch, Dubina, Wilson) reversed the denial of habeas relief to an Alabama inmate sentenced to death for a 1988 murder.
The Court found that Williams’ counsel were ineffective at the sentencing stage in failing to broaden the scope of their investigation with regard to Williams’ life history. As a result, counsel "obtained an incomplete and misleading understanding of Williams’ life history." Minimal investigation would have led counsel to follow up on the information about Williams’ psychological problems chronicled in reports, and to interview family members who could corroborate evidence of abuse.
The Court found that Williams was prejudiced by counsel’s failure to investigate, because the evidence of Williams’ repeated beatings in childhood was not presented. Further, the murder here was not "highly aggravated," as evidenced by the fact that the jury recommended a life-sentence by a 9-3 vote (the judge nonetheless imposed the death sentence). The Court held that the Alabama Supreme Court decision, which found no prejudice, was an unreasonable application of Strickland, because the mitigating evidence, taken as a whole, "might have altered the trial judge’s appraisal of Williams’ moral culpability."
