The United States District Court for the Northern District of Alabama granted federal habeas relief to Alabama death row prisoner William Glenn Boyd on September 28, 2007.
Mr. Boyd claimed that his trial lawyer was ineffective for failing to investigate and present mitigating evidence to the jury or the trial judge, including a wealth of evidence that his character had been shaped by a childhood characterized by continual gross poverty, physical and emotional abuse, neglect, and humiliations at the hands of his cruel and alcoholic father and stepfather, mentally disturbed mother, and loving but severely alcoholic grandparents. The federal district court held that the Alabama Court of Criminal Appeals, in finding that counsel’s failure to present mitigating was the product of a strategic decision, “ignored clear and convincing evidence establishing that defense counsel did not devise a professionally-competent, mitigation ‘strategy’ prior to trial, nor did they make an informed ‘tactical choice’ to present the penalty-phase case in the manner it was put before the jury.”
Initially, the federal court nonetheless denied relief to Mr. Boyd, finding that he was not prejudiced by counsel’s failures because the majority of jurors recommended that he be sentenced to life without parole. The court reversed itself in response to Mr. Boyd’s motion for reconsideration and found that its “previous analysis, and also that of the Alabama Court of Criminal Appeals, was erroneous for failing to properly weigh, according to constitutional standards, the additional mitigating evidence presented to the Rule 32 court when determining that Boyd had not shown prejudice from his attorneys’ failure to present that evidence to the trial court judge during the sentencing hearing; and, as such, this court and the state court rendered a decision contrary to clearly established federal law.”
Rejecting the state court’s notion that evidence of Mr. Boyd’s troubled background could only be significant mitigation if it was causally connected to the crime, the federal court held that trial counsel’s failure to present mitigation evidence like that in Williams v. Taylor, 529 U.S. 362, 395-98 (2000), Wiggins v. Smith, 539 U.S. 510, 516, 524-25 (2003), and Skipper v. South Carolina, 476 U.S. 1, 3 (1986), to the trial judge as well as the jury was ineffective assistance that violated Mr. Boyd’s Sixth Amendment right to counsel.
The court also found that Mr. Boyd’s claim that a juror was exposed to extraneous evidence was not procedurally barred where Mr. Boyd raised the claim in the proper manner but was arbitrarily denied the opportunity to disprove the procedural bar raised by the State, and where Mr. Boyd’s proffers and the record shows that trial counsel could not have known about the extraneous evidence. Relief was denied on the merits, however, because the jury was aware of the information from witnesses who testified at trial.