Criminal Law

Strickland v. Washington — Study Notes

466 U.S. 668 (1984)

Study notes for Strickland v. Washington: professor notes, cold call prep, exam angles, and memory aids.

To prove ineffective assistance of counsel, a defendant must show that their attorney's performance was deficient and that this deficiency resulted in prejudice that affected the trial's outcome.
Professor Notes

Strickland v. Washington is a landmark case that established the standard for effective assistance of counsel. Professors emphasize the two-pronged test that defendants must meet in order to succeed on an ineffective assistance of counsel claim: showing that their attorney's performance was deficient and that such deficiency prejudiced their defense. The case underscores the importance of competent legal representation and defines how courts evaluate whether a fundamental right has been violated during the criminal process. Professors also highlight the implications of the ruling on future case law and defense strategies in capital cases.

Cold Call Prep
  1. 1What are the two prongs of the Strickland test?
  2. 2How did the Supreme Court define 'deficient performance'?
  3. 3What does 'prejudice' mean in the context of this case?
  4. 4Can you summarize the factual background of Strickland v. Washington?
  5. 5How does this case impact the standards for attorneys in capital cases?
  6. 6What are some examples of performance deficiencies that might satisfy Strickland's first prong?
  7. 7What public policy concerns might arise in litigation over ineffective assistance of counsel?
Mnemonic Device

PRP - Performance and Prejudice for Strickland's Rule.

Distinguish From
CaseDistinction
United States v. CronicCronic involved an automatic presumption of prejudice due to lack of counsel, whereas Strickland requires proof of both deficient performance and resulting prejudice.
Hill v. LockhartHill addressed ineffective assistance in the context of guilty pleas but used the same Strickland framework for evaluating counsel's performance and its impact on the plea decision.
Roe v. Flores-OrtegaFlores-Ortega explored the effectiveness of counsel in the context of failing to file a notice of appeal, also applying the Strickland standard but focusing on the specific consequences of that failure.
Policy Arguments

For the Rule

The Strickland rule promotes the constitutional right to effective legal representation, ensuring that defendants have a fair trial and that the adversarial system functions as intended.

Against the Rule

Critics argue that the Strickland standard is too lenient, allowing courts to overlook clear instances of ineffective assistance, which can undermine the integrity of the legal process.

Class Discussion Points
  • Discuss the impact of Strickland on capital punishment cases and the responsibility of defense attorneys.
  • Explore how the Strickland test might apply in different types of criminal cases beyond capital felonies.
  • Evaluate potential reforms that could strengthen the right to effective counsel based on the lessons from Strickland.
Exam Angle

Strickland v. Washington frequently appears on exams regarding the Sixth Amendment and ineffective assistance of counsel claims. Students should be prepared to analyze specific situations where counsel's performance may be challenged and apply the two-pronged Strickland test to hypothetical scenarios.

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