Ineffective assistance of counsel

Saranchak v. Sec'y, Pa. Dep't of Corr., 802 F.3d 579 (3d Cir. 2015)

Failure of defense counsel to present mitigation evidence regarding defendant’s history of mental illness in sentencing phase of murder trial was prejudicial

Background: Following affirmance of his state court conviction for first degree murder and sentence of death, and denial of his motion for state post-conviction relief, Daniel Saranchak filed a petition for a federal writ of habeas corpus. The United States District Court for the Middle District of Pennsylvania granted the petition in part, but the Third Circuit Court of Appeals reversed and remanded. On remand, the District Court denied the petition. Saranchak appealed the denial, claiming that (1) his attorney’s cumulative errors at trial prejudiced the guilt phase of the trial, and (2) his attorney was constitutionally ineffective at the penalty phase of his trial.

Holdings: The Third Circuit Court of Appeals, hearing Saranchak’s appeal for the second time, held that Saranchak was not prejudiced by trial counsel’s failure to present evidence of Saranchak’s mental health history in conjunction with the admission of his confession. It did, however, find that the district court had been unreasonable in finding that (1) the background information available to trial counsel was insufficient to prompt further investigation regarding Saranchak’s mental health, and (2) petitioner was not denied effective assistance due to this failure to investigate.

The Third Circuit found that Saranchak’s trial counsel had access to enough background information regarding the client to warrant further investigation regarding Saranchak’s mental health. The Third Circuit pointed to specific “red flags”: (1) Saranchak stated that he was treated for one-month at an inpatient clinic; (2) Saranchak had once ingested 250 pills in response to his wife having an affair; and (3) a neutral expert noted that Saranchak “appeared to suffer from a personality disorder” with antisocial traits.

The Third Circuit also held that this failure to investigate amounted to ineffective assistance of counsel because counsel believed that Saranchak’s mental health was a major issue in the case. Additionally, none of the petitioner’s psychological diagnoses were presented to the jury, and “additional evidence revealed that petitioner’s troubled past and psychological problems were significant factors affecting his life.” This met the prejudice test required by Strickland. 

Found in Found in DMHL Volume 34, Issue 4