Jones v. Ryan

IAC claims require the defendant to show that (1) “counsel’s performance was deficient,” and (2) “the deficient performance prejudiced the defense.” Strickland v. Washington, 466 U.S. 668, 687 (1984). Counsel’s failure to investigate and present evidence of a defendant’s mental defect constitutes deficient performance. Williams v. Taylor, 529 U.S. 362, 396 (2000). Additionally, the failure to “make even [a] cursory investigation” into available means of obtaining additional funding for expert witnesses may amount to deficient performance under Strickland. See Hinton v. Alabama, 571 U.S. 263, 274 (2014).

Jones was indicted on multiple murder-related charges. At trial, his public defender requested $5,000 for expert witnesses and was only granted $2,000, which he neglected to spend on securing a mental health expert. Counsel instead relied on the court-appointed expert’s testimony. After receiving a death penalty sentence, Jones asserted an ineffective assistance of counsel (IAC) claim, arguing that his trial counsel was constitutionally ineffective because they failed to secure a mental health expert to provide mitigating evidence during the capital sentencing phase of his trial. IAC claims require the defendant to show that (1) “counsel’s performance was deficient,” and (2) “the deficient performance prejudiced the defense.” Strickland v. Washington, 466 U.S. 668, 687 (1984).  Counsel’s failure to investigate and present evidence of a defendant’s mental defect constitutes deficient performance. Williams v. Taylor, 529 U.S. 362, 396 (2000). Additionally, the failure to “make even [a] cursory investigation” into available means of obtaining additional funding for expert witnesses may amount to deficient performance under Strickland. See Hinton v. Alabama, 571 U.S. 263, 274 (2014). The record demonstrated that Counsel was aware of Jones’ possible mental impairment and failed to investigate that condition as a mitigating factor. The court-appointed expert’s evaluation was insufficient to support Jones’ case because that expert had no obligation to protect or further the defense’s interests, nor was the evaluation confidential. Because the record established that evidence provided by a mental health expert for the defense would have been more probative and persuasive in reducing Jones’ culpability, his defense was prejudiced by this deficient performance. Counsel’s failure to request additional funding from his supervisor or the court for the purpose of securing that mitigating evidence likewise constituted deficient performance prejudicing Jones. He is therefore entitled to relief and resentencing. Reversed and remanded.