Florida v. Nixon case brief

Florida v. Nixon case brief summary
543 U.S. 175 (2004)

CASE SYNOPSIS

Defendant was convicted of murder and sentenced to death, but defendant asserted that his counsel was ineffective for conceding defendant's guilt during the trial phase without obtaining defendant's express consent. Upon the grant of a writ of certiorari, respondent State appealed the judgment of the Florida Supreme Court which held that defendant received ineffective assistance of counsel.

CASE FACTS

• In view of overwhelming evidence of defendant's guilt of the brutal murder, including defendant's confession, counsel advised defendant that the best course was to concede guilt at the trial phase and present extensive mitigation evidence of defendant's mental instability during the penalty phase. 
• Upon receiving no response from the uncommunicative defendant, counsel proceeded to concede guilt, and defendant contended that effectively pleading guilty without defendant's consent was presumptively prejudicial. 

DISCUSSION
The United States Supreme Court unanimously held, however, that the concession of guilt without explicit consent of defendant was not automatically prejudicial ineffective assistance of counsel. Defendant neither consented nor objected to counsel's proposed strategy and counsel acted reasonably in electing the most promising means of averting the death penalty. Further, the concession was not tantamount to a guilty plea since defendant retained his criminal trial and appeal rights, and counsel could not be deemed ineffective for attempting to impress the jury with his candor which could lend credence to counsel's mitigation efforts during the penalty phase.

CONCLUSION
The judgment holding that defendant received ineffective assistance of counsel was reversed, and the case was remanded for further proceedings.



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