Bell v. Cone
Bell v. Cone, 535 U.S. 685 (2002), was a Supreme Court of the United States case that upheld a death sentence despite the defendant's argument that he should not be sentenced to death because he was suffering from drug-induced psychosis when he committed the crimes. Cone also argued that he was denied effective assistance of counsel because his attorney failed to present sufficient mitigating evidence during the sentencing phase of his trial and that his attorney inappropriately waived his final argument during the sentencing phase. In an 8–1 opinion written by Chief Justice William Rehnquist, the United States Supreme Court denied Cone's petition for a writ of habeas corpus. The Court held that the actions taken by Cone's attorney during the sentencing phase were "tactical decisions" and that the state courts that denied Cone's appeals did not unreasonably apply clearly established law. Justice John Paul Stevens wrote a dissenting opinion in which he argued that Cone was denied effective assistance of counsel because his attorney failed to "subject the prosecution's case to meaningful adversarial testing."
| Bell v. Cone | |
|---|---|
Supreme Court of the United States | |
| Argued March 25, 2002 Decided May 28, 2002 | |
| Full case name | Ricky Bell, Warden v. Gary Bradford Cone |
| Docket no. | 01-400 |
| Citations | 535 U.S. 685 (more) 122 S. Ct. 1843; 152 L. Ed. 2d 914 |
| Argument | Oral argument |
| Case history | |
| Prior | Cone v. Bell, 956 F. Supp. 1401 (W.D. Tenn. 1997); affirmed in part, reversed in part, 243 F.3d 961 (6th Cir. 2001); cert. granted, 534 U.S. 1064 (2001). |
| Subsequent | Cone v. Bell, 359 F.3d 785 (6th Cir. 2004), reversed and remanded by Bell v. Cone, 543 U.S. 447 (2005) (per curiam); Cone v. Bell, 492 F.3d 743 (6th Cir. 2007), vacated by Cone v. Bell, 556 U.S. 449, 463 (2009). |
| Holding | |
| Tennessee state courts did not unreasonably apply clearly established law when determining whether the defendant in this case was denied effective assistance of counsel | |
| Court membership | |
| |
| Case opinions | |
| Majority | Rehnquist, joined by O'Connor, Scalia, Kennedy, Souter, Thomas, Ginsburg, Breyer |
| Dissent | Stevens |
| Laws applied | |
| Antiterrorism and Effective Death Penalty Act of 1996, | |
Commentators have noted that Bell v. Cone is significant because it clarified the standards that should be used when determining ineffective assistance of counsel claims. Other commentators have suggested that the Court's ruling has made it more difficult for state prisoners to receive habeas relief in federal court. After several additional appeals, the United States Supreme Court ruled in Cone v. Bell (2009) that Cone should receive a new hearing in federal trial court to determine whether the prosecution's failure to disclose evidence violated Cone's rights to due process under Brady v. Maryland. In 2016, Gary Cone died from natural causes while still sitting on Tennessee's death row.