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| '''''McCoy v. Louisiana''''', 584 U.S. ___ (2018), was a ] case in which the Court held the ] guarantees a defendant the right to decide that the objective of his defense is to maintain innocence at all costs, even when counsel believes that admitting guilt offers the defendant the best chance to avoid the death penalty. | '''''McCoy v. Louisiana''''', 584 U.S. ___ (2018), was a ] case in which the Court held the ] guarantees a defendant the right to decide that the objective of his defense is to maintain innocence at all costs, even when counsel believes that admitting guilt offers the defendant the best chance to avoid the death penalty. | ||
| == Facts and Procedural History == | |||
| == Background == | |||
| In 2008, Louisiana resident Robert McCoy was charged with the murder of his estranged wife's son, mother, and step-father; the prosecution sought the death penalty.<ref>''McCoy'', 138 S. Ct. at 1505-06.</ref> He was initially appointed counsel from the public defender's office, but intractable disagreements arose, and he discharged his public defender.<ref name=":0">''McCoy'', 138 S. Ct. at 1506.</ref> McCoy's parents hired a new lawyer, Larry English.<ref name=":0" /> | |||
| In 2008, Louisiana resident Robert McCoy was charged with the murder of the son, mother and step-father of his estranged wife. His trial was held in mid-2011; as a ], the trial was divided into two phases, the first to determine if McCoy was guilty of the crime, and the second to determine the sentencing. McCoy's lawyer, Larry English, felt that the evidence in the case pointed towards McCoy's guilt, and in meeting with McCoy before the trial, said that he would have McCoy plead guilty so that he can focus on obtaining a life-in-prison sentence rather than a death sentence. McCoy protested, stating he was innocent of the crime, and attempted to have English removed as his legal counsel, but the presiding judge refused. English proceeded with the not guilty plea.{{Clarify|date=October 2018}} The jury ended up sentencing McCoy on three counts of first-degree murder and giving him a death sentence.<ref name="nytimes bg">{{Cite news | url = https://www.nytimes.com/2017/10/09/us/politics/death-penalty-supreme-court-attorney.html | title = Facing the Death Penalty With a Disloyal Lawyer | first= Adam | last = Liptak | date = October 7, 2017 | accessdate = May 15, 2018 | work = ] }}</ref> | |||
| As McCoy was charged with a ], his trial was divided into two phases: a "guilt phase" to determine if McCoy was guilty of the crime, and a "penalty phase" to determine the sentencing. English believed the evidence against McCoy was overwhelming and saw no hope of winning an acquittal.<ref name=":0" /> Instead, English formulated a trial strategy based on conceding at the guilt phase that McCoy was the killer in the hope of avoiding a death sentence at the penalty phase.<ref name=":0" /> When English explained this strategy to McCoy, he protested, insisting he was innocent of the crime and seeking to have English removed as his counsel.<ref name=":0" /> With only two days before trial was set to begin, the presiding judge refused.<ref name=":0" /> English proceeded with his strategy, telling the jury there was no way they could conclude that McCoy was innocent based on the evidence at trial.<ref>''McCoy'', 138 S. Ct. at 1506-07.</ref> McCoy testified in his own defense, presenting a complex alibi<ref name=":1">''McCoy'', 138 S. Ct. at 1507.</ref> involving an interstate police conspiracy to frame him.<ref>''McCoy'', 138 S. Ct. at 1513 (Alito, J., dissenting).</ref> The jury convicted him of all three homicides.<ref name=":1" /> | |||
| McCoy, with new legal counsel, appealed to the ], arguing that his lawyer had betrayed him. The Court ruled against McCoy, relying on the U.S. Supreme Court decision in ''Florida v. Nixon'',<ref>{{ussc|name=Florida v. Nixon|543|175|2004}}.</ref> that determined that a lawyer did not need to seek their client's express consent before entering a plea of guilty for them.<ref name="nytimes bg"/> | |||
| During the penalty phase, English argued that the jury should have mercy on McCoy in light of his "serious mental and emotional issues."<ref name=":1" /> The jury reached a death verdict on each count.<ref name=":1" /><ref>''Nixon'', 543 U.S. at 192.</ref> | |||
| McCoy appealed to the ], arguing that the trial court should not have allowed English to concede over McCoy's objections.<ref name=":1" /> The court ruled against McCoy, relying on the U.S. Supreme Court's decision in '']'',<ref>543 U.S. 175 (2004).</ref> which determined that a lawyer could concede the defendant's guilt where the defendant neither expressly objected to nor opposed making such a concession.<ref name="nytimes bg">{{Cite news | url = https://www.nytimes.com/2017/10/09/us/politics/death-penalty-supreme-court-attorney.html | title = Facing the Death Penalty With a Disloyal Lawyer | first= Adam | last = Liptak | date = October 7, 2017 | accessdate = May 15, 2018 | work = ] }}</ref> | |||
| == Supreme Court == | == Supreme Court == | ||
Revision as of 00:16, 14 March 2019
2018 United States Supreme Court case| McCoy v. Louisiana | |
|---|---|
 Supreme Court of the United States | |
| Argued January 17, 2018 Decided May 14, 2018 | |
| Full case name | McCoy v. Louisiana |
| Docket no. | 16-8255 |
| Citations | 584 U.S. ___ (more)138 S. Ct. 1500; 200 L. Ed. 2d 821 |
| Case history | |
| Prior | State v. McCoy, 218 So. 3d 535 (La. 2016); cert. granted, 138 S. Ct. 53 (2017). |
| Subsequent | On remand, 251 So. 3d 399 (La. 2018). |
| Holding | |
| The Sixth Amendment guarantees a defendant the right to choose the objective of his defense and to insist that his counsel refrain from admitting guilt, even when counsel's experienced-based view is that confessing guilt offers the defendant the best chance to avoid the death penalty. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Ginsburg, joined by Roberts, Kennedy, Breyer, Sotomayor, Kagan |
| Dissent | Alito, joined by Thomas, Gorsuch |
McCoy v. Louisiana, 584 U.S. ___ (2018), was a United States Supreme Court case in which the Court held the Sixth Amendment guarantees a defendant the right to decide that the objective of his defense is to maintain innocence at all costs, even when counsel believes that admitting guilt offers the defendant the best chance to avoid the death penalty.
Facts and Procedural History
In 2008, Louisiana resident Robert McCoy was charged with the murder of his estranged wife's son, mother, and step-father; the prosecution sought the death penalty. He was initially appointed counsel from the public defender's office, but intractable disagreements arose, and he discharged his public defender. McCoy's parents hired a new lawyer, Larry English.
As McCoy was charged with a capital offense, his trial was divided into two phases: a "guilt phase" to determine if McCoy was guilty of the crime, and a "penalty phase" to determine the sentencing. English believed the evidence against McCoy was overwhelming and saw no hope of winning an acquittal. Instead, English formulated a trial strategy based on conceding at the guilt phase that McCoy was the killer in the hope of avoiding a death sentence at the penalty phase. When English explained this strategy to McCoy, he protested, insisting he was innocent of the crime and seeking to have English removed as his counsel. With only two days before trial was set to begin, the presiding judge refused. English proceeded with his strategy, telling the jury there was no way they could conclude that McCoy was innocent based on the evidence at trial. McCoy testified in his own defense, presenting a complex alibi involving an interstate police conspiracy to frame him. The jury convicted him of all three homicides.
During the penalty phase, English argued that the jury should have mercy on McCoy in light of his "serious mental and emotional issues." The jury reached a death verdict on each count.
McCoy appealed to the Louisiana Supreme Court, arguing that the trial court should not have allowed English to concede over McCoy's objections. The court ruled against McCoy, relying on the U.S. Supreme Court's decision in Florida v. Nixon, which determined that a lawyer could concede the defendant's guilt where the defendant neither expressly objected to nor opposed making such a concession.
Supreme Court
In March 2017, McCoy petitioned the United States Supreme Court to hear his argument on whether legal counsel could go against his expressed objections to pleading guilty, citing the Sixth Amendment. The Court agreed to hear the case and scheduled oral arguments for January 17, 2018.
The Court issued its ruling on May 14, 2018. In a 6–3 decision, the Court found in favor of McCoy and held that, under the Sixth Amendment, a defendant has the right to choose the objective of their defense and can constrain their legal counsel from admitting guilt. The majority opinion was written by Justice Ruth Bader Ginsburg and joined by Justices John Roberts, Anthony Kennedy, Stephen Breyer, Sonia Sotomayor, and Elena Kagan. Ginsburg wrote in her opinion, "Even when a criminal defendant is assisted by counsel, some decisions are reserved for the client." The Supreme Court overturned McCoy's convictions and ordered that McCoy be given a new trial.
Justice Samuel Alito wrote the dissenting opinion joined by Justices Clarence Thomas and Neil Gorsuch. Alito wrote that while English had argued that McCoy had killed the victims, he did not plead McCoy guilty of first-degree murder, thus consistent with McCoy's request. Alito considered the evidence against McCoy overwhelming, such that a retrial would unlikely find a different result.
References
- McCoy, 138 S. Ct. at 1505-06.
- ^ McCoy, 138 S. Ct. at 1506.
- McCoy, 138 S. Ct. at 1506-07.
- ^ McCoy, 138 S. Ct. at 1507.
- McCoy, 138 S. Ct. at 1513 (Alito, J., dissenting).
- Nixon, 543 U.S. at 192.
- 543 U.S. 175 (2004).
- Liptak, Adam (October 7, 2017). "Facing the Death Penalty With a Disloyal Lawyer". The New York Times. Retrieved May 15, 2018.
- ^ Sherman, Mark (May 14, 2018). "Supreme Court rules for inmate whose lawyer conceded guilt". The Washington Post. Retrieved May 15, 2018.
- ^ Liptak, Adam (May 14, 2018). "Supreme Court Rules for Death Row Inmate Betrayed by His Lawyer". The New York Times. Retrieved May 15, 2018.
External links
- Text of McCoy v. Louisiana, 584 U.S. ___ (2018) is available from: Justia Oyez (oral argument audio) Supreme Court (slip opinion)
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