Based on Procedural Rules, Supreme Court Upholds Alabama Death Sentence


The Supreme Court today denied relief in Wood v. Allen, an Alabama case which asked the Court to address whether trial lawyers performed adequately when they failed to investigate and present evidence of intellectual disability. The decision focused on the procedural rules that limit federal habeas corpus review and did not reach the merits of Mr. Woods’s claim.

Holly Wood’s appointed lawyer—who was just months out of law school—did not pursue evidence of his severe mental impairments even though a competency evaluation revealed that Mr. Wood read at a third-grade level and had a low IQ. Mr. Wood was convicted and sentenced to death.

The Supreme Court later ruled that people with intellectual disability cannot be executed.

Mr. Wood argued in state postconviction proceedings that his lawyer did not perform adequately and deprived him of his constitutional right to counsel. The state court disagreed, but the federal district found that his lawyer was ineffective and ordered a new penalty phase trial. The Eleventh Circuit Court of Appeals reversed.

Today, the Supreme Court affirmed without addressing whether Mr. Wood’s lawyer made a reasonable strategic decision to keep mitigating evidence from the jury. Relying on the procedural restrictions of federal habeas corpus review, the Court found it could not reverse the state court judgment – even if it is wrong – because it was not unreasonable.

Justices Stevens and Kennedy dissenting, writing that “Wood has the type of significant mental deficits that we recognize as ‘inherently mitigating.'” The dissent concluded that “the failure to investigate was the product of inattention and neglect by attorneys preoccupied with other concerns.”

Alabama is the only state in the country without a state-funded program to provide legal assistance to death row prisoners. There is no state-wide public defender program and half of the 200 people on Alabama’s death row, including Mr. Wood, were represented at trial by appointed lawyers whose compensation for out-of-court preparation was capped at $1000.