Monday, December 23, 2013

United States v. Cronic case brief

United States v. Cronic case brief summary
466 U.S. 648 (1984)

CASE SYNOPSIS
The United States appealed from the order of the United States Court of Appeals for the Tenth Circuit that reversed respondent's conviction for mail fraud on the basis that he was denied effective assistance of counsel in violation of U.S. Constitutional Amendment VI.

CASE FACTS
Respondent was indicted on mail fraud charges, and shortly before trial, his retained counsel withdrew. The trial court appointed a young lawyer with a real estate practice to represent respondent, and 25 days were allowed for pretrial preparation even though it had taken the government over four and one-half years to prepare the case. Respondent was convicted on 11 of 13 counts and sentenced to 25 years in prison. The court of appeals reversed the conviction on the basis of ineffective assistance of counsel.

DISCUSSION
  • The Court granted the government's petition for certiorari and reversed and remanded, holding that the criteria used by the court of appeals did not prove that counsel's defense was ineffective. 
  • Counsel's preparation time and his inexperience did not justify a presumption of ineffectiveness. 
  • Also, the gravity of the charge, the complexity of the case, and the accessibility of witnesses were not circumstances, in themselves, that made it unlikely that respondent received effective assistance of counsel. 
  • The Court concluded that, on remand, respondent could make out an ineffective assistance claim only by alleging specific errors made by trial counsel.
CONCLUSION
The Court reversed and remanded the order of the court of appeals that reversed respondent's conviction for mail fraud on the basis of ineffective assistance of counsel because counsel's trial preparation time, counsel's inexperience, the gravity of the charge against respondent, the complexity of the case, and the accessibility of witnesses were not circumstances that made it unlikely that respondent received effective assistance of counsel.


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