Sotomayor Opinion Upholds Death Sentence for Lower-IQ Inmate
The U.S. Supreme Court in an opinion by Justice Sonia Sotomayor has upheld a death sentence for an Alabama inmate who claimed his counsel was ineffective for failing to introduce evidence of his low IQ.
The state court was not unreasonable when it found that lawyers for defendant Holly Wood made a strategic decision not to present evidence of their client’s subaverage intellect, Sotomayor, a former prosecutor, wrote in the majority opinion (PDF). Wood, who had an IQ less than 70, was convicted of killing a former girlfriend.
The state court found that counsel’s failure to present the IQ findings was a deliberate decision to focus on other decisions rather than mere neglect or oversight. Sotomayor elaborated on why the finding wasn’t unreasonable in a footnote addressing a dissent by Justices John Paul Stevens and Anthony M. Kennedy.
“Evidence about Wood’s mental deficiencies may have led to rebuttal testimony about the capabilities he demonstrated through his extensive criminal history, an extraordinarily limited amount of which was actually admitted at the penalty phase of the trial,” Sotomayor wrote. “Counsel’s decision successfully thwarted the prosecutor’s efforts to admit evidence that Wood murdered his ex-girlfriend while on parole for an attempted murder of a different ex-girlfriend that was strikingly similar in execution to the subsequent successful murder.”
Stevens argued in his dissent that Wood’s counsel sensibly kept the IQ report out of the guilt phase of the trial, but his lawyers should have further investigated the mental defects for the penalty phase. The defense lawyer who had primary responsibility for the penalty phase had only five months’ experience, Stevens wrote.
Stevens said the only conclusion he can draw from the evidence was that the defense team’s failure to investigate was “the product of inattention and neglect by attorneys preoccupied with other concerns and not the product of a deliberate choice between two permissible alternatives.”
The case is Wood v. Allen.
Related coverage:
Associated Press: “Court upholds death sentence for Ala. Man”
