Supreme Court to Review Woods v. Donald
This term the U.S. Supreme Court granted review of a Michigan case, Woods v. Donald. Out of all the cases that come before the Court for review, only about 1% get chosen to be heard per term.
In the mid-eighties, the Court held in a case called Cronic that when a defendant was attempting to show that his or her attorney was ineffective, there needed to be some impact on the reliability on the trial itself, except under a few extreme circumstances. One such situation is the total denial of an attorney at a critical stage of a defendant’s trial. Yet, the phrase “critical stage” has not been defined since.
In the present case, the Sixth Circuit decided to apply this to a situation where the defendant’s attorney was absent for a 10 minute period during a trial that involved multiple defendants. During that time, the testimony presented never mentioned the defendant at all.
Michigan’s Court of Appeals decided that this situation was not an extreme circumstance that met the presumption of prejudice as described in Cronic. In addition, the Court found the defendant was not entitled to relief because there was no demonstration that prejudice occurred.
The Sixth Circuit did not find a U.S. Supreme Court case that held that the taking of evidence during a trial―with single or multiple defendants―is in itself a critical stage that triggered the presumption of prejudice, signaling an unfair trial. However, the Court still held that the Michigan Court of Appeals unreasonably applied Cronic and the defendant was entitled to habeas relief.
Habeas proceedings are where a petitioner can make federal claims on issues that have already been presented in state courts. In turn, the court can uphold both the conviction and sentence, or grant a petition for relief and modify a sentence, order a new trial, or provide other relief as appropriate.
Oral arguments have not been heard yet by the U.S. Supreme Court. However, the outcome of this case is much anticipated. The issues at stake are important because a defendant’s right to the effective assistance of counsel matters. It directly affects the ability to receive a fair trial.