Medina v. Chappell

A court must take into account all mitigating evidence to evaluate whether a defendant has been prejudiced because of ineffective counsel.

In 1984, Teofilo Medina, Jr. committed four murders in California. The first three murders occurred in Orange County, where he was found guilty of robbing three businesses and killing an employee at each location. The fourth murder occurred in Riverside County where Medina was found guilty of robbing a gas station and killing the employee. During the Orange County trial, Medina was found competent to stand trial, and the jury rejected Medina’s insanity defense. Medina filed a habeas petition in the Orange County conviction before the Anti-Terrorism and Effective Death Penalty Act (“AEDPA”) was in effect. However, Medina filed a habeas petition in the Riverside County conviction after the AEDPA took effect. The district court denied both petitions. On appeal, the Ninth Circuit upheld the district court’s decision in the Orange County conviction, finding Medina’s counsel to be effective despite counsel failing to more thoroughly investigate Medina’s childhood. Additionally, the panel rejected Medina’s argument that his trial counsel was ineffective at the penalty phase because counsel did not present evidence that supported Medina’s insanity claim. The panel agreed with Medina that trial counsel erred by not objecting to expert testimony that schizophrenia can be faked; nevertheless, this error did not prejudice Medina under Strickland v. Washington. In the Riverside County conviction, the AEDPA was effective, but the California Supreme Court had not issued an opinion about Medina’s ineffective counsel claim. The panel held that a fair-minded jurist could disagree on whether the trial counsels’ deficient performance prejudiced Medina. AFFIRMED.