Dunn v. Reeves
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Dunn v. Reeves and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Dunn v. Reeves.
The Supreme Court reviewed whether the Eleventh Circuit erred in reversing an Alabama court's decision denying postconviction relief to Reeves, who claimed ineffective assistance of counsel. The Alabama court had denied relief due to a lack of evidence from trial counsel, while the Eleventh Circuit found this approach unreasonable. The Supreme Court reversed the Eleventh Circuit, emphasizing the presumption of reasonableness afforded to strategic decisions made by counsel.
Holding
The single most important “bottom line” of what the Court decided in Dunn v. Reeves.
The Court held that the Eleventh Circuit erred in characterizing the Alabama court's analysis as a categorical rule requiring testimony from trial counsel to prove ineffective assistance.
Constitutional Concepts
These are the Constitution-related themes that appear in Dunn v. Reeves. Click a concept to see other cases that involve the same idea.
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Why Right to Counsel is relevant to Dunn v. Reeves
The case centers on whether Reeves' trial counsel was constitutionally deficient for not hiring an expert to develop evidence of intellectual disability, implicating the right to effective assistance of counsel.
Syllabus excerpt (verbatim)The Eleventh Circuit held that Reeves' lawyers were constitutionally deficient for not developing more evidence of intellectual disability and that this failure might have changed the outcome of the trial.
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Why Procedural Due Process is relevant to Dunn v. Reeves
The case involves procedural aspects of how ineffective assistance of counsel claims should be evaluated, including the requirement of presenting evidence from trial counsel.
Syllabus excerpt (verbatim)The Eleventh Circuit characterized the state court's decision as having applied a categorical rule that any prisoner will always lose if he fails to call and question trial counsel regarding his or her actions and reasoning.
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Why Judicial Review is relevant to Dunn v. Reeves
The case involves the federal court's review of a state court decision under habeas corpus standards, assessing whether the state court's decision was contrary to clearly established federal law.
Syllabus excerpt (verbatim)A federal court may grant habeas relief only if a state court violated 'clearly established Federal law, as determined by the Supreme Court of the United States.'
Key Quotes
Short excerpts from the syllabus in Dunn v. Reeves that support the summary and concepts above.
The Eleventh Circuit erred in characterizing the Alabama court's case-specific analysis as a 'categorical rule.'
Strategic decisions—including whether to hire an expert—are entitled to a 'strong presumption' of reasonableness.
A federal court may grant habeas relief only if a state court violated 'clearly established Federal law.'
