McCoy v. Louisiana

McCoy v. Louisiana
Argued January 17, 2018
Decided May 14, 2018
Full case name McCoy v. Louisiana
Docket nos. 16-8255
Citations 584 U.S. ___ (more)
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
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan · Neil Gorsuch
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 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.[1]

Background

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 capital offense, 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 council, but the presiding judge refused. English proceeded with the not guilty plea. The jury ended up sentencing McCoy on three counts of first-degree murder and giving him a death sentence.[2]

McCoy, with new legal counsel, appealed to the Louisiana Supreme Court, arguing that his lawyer had betrayed him. The Court ruled against McCoy, relying on the Supreme Court decision in Florida v. Nixon, 543 U.S. 175 (2004), that determined that a lawyer did not need to seek their client's express consent before entering a plea of guilty for them.[2]

Supreme Court

In March 2017, McCoy petitioned the Supreme Court to hear his argument on whether legal council can go against his expressed objections to pleading guilty, citing the Sixth Amendment. The Court agreed to hear the case by September 2017, and scheduled oral arguments for January 17, 2018.

The Court issued its ruling on May 14, 2018, in a 6–3 decision that found in favor of McCoy that under the Sixth Amendment, a defendant has the right to choose the objective of their defense, and can refrain their legal council 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.[3][4]

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.[3][4]

References

  1. ↑ "McCoy v. Louisiana, 584 U.S. ___ (2018)". Justia. Retrieved 15 May 2018.
  2. 1 2 Liptak, Adam (October 7, 2017). "Facing the Death Penalty With a Disloyal Lawyer". The New York Times. Retrieved May 15, 2018.
  3. 1 2 Sherman, Mark (May 14, 2018). "Supreme Court rules for inmate whose lawyer conceded guilt". The Washington Post. Retrieved May 15, 2018.
  4. 1 2 Liptak, Adam (May 14, 2018). "Supreme Court Rules for Death Row Inmate Betrayed by His Lawyer". The New York Times. Retrieved May 15, 2018.
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