Florida v. Nixon
United States Supreme Court
543 U.S. 175 (2004)
After confessing to a brutal murder, Nixon (defendant) refused to meaningfully participate in his own defense; his appointed counsel, Corin, concluded guilt was not seriously in question, tried unsuccessfully to negotiate a plea, and settled on a strategy of conceding guilt at trial to focus more credibly on seeking mercy at sentencing, attempting three times to consult Nixon about this plan without ever getting his consent or objection. Nixon became so disruptive at trial that he was removed and later waived his right to be present; Corin proceeded with the planned concession and presented extensive mitigating evidence, but the jury convicted Nixon and sentenced him to death, and the Florida Supreme Court overturned the conviction for lack of Nixon's express consent to the concession strategy.
Whether a criminal defendant is entitled to reversal on ineffective-assistance grounds where his attorney conceded guilt at trial as a sentencing strategy without obtaining the defendant's express consent.