Williams v. Stirling, No. 18-2 (4th Cir. 2019)Annotate this Case
Petitioner sought habeas relief under 28 U.S.C. 2254 after he was convicted of crimes related to the murder of his ex-girlfriend and sentenced to death. The district court denied or stayed all of petitioner's claims, except Ground Six, which asserted a claim of ineffective assistance of counsel resulting from trial counsel's failure to investigate potentially mitigating evidence of Fetal Alcohol Syndrome (FAS).
The Fourth Circuit affirmed and held that counsel's investigation into potentially mitigating evidence of FAS failed to meet an objective standard of reasonableness. Therefore, the postconviction relief court erred in concluding that petitioner had failed to establish deficient performance by counsel. Furthermore, the district court correctly determined that petitioner had established prejudice under Strickland v. Washington. Therefore, the postconviction relief court's prejudice determination was contrary to or an unreasonable application of Supreme Court precedent, or an objectively unreasonable factual determination.
The court issued a subsequent related opinion or order on February 5, 2019.