Hurrell-Harring v. State of New York
Court of Appeals of New York
930 N.E.2d 217 (N.Y. 2010)
A class of similarly situated indigent criminal defendants (plaintiffs) sued New York State (defendant), alleging the state's system for providing appointed counsel was so deficient that defendants routinely went unrepresented at arraignments, appointed attorneys were frequently unavailable or unresponsive, missed court appearances, showed up unprepared, and waived important rights without ever consulting their clients. The lower court dismissed, reasoning that ineffective-assistance claims are inherently case-specific under Strickland v. Washington and therefore not suitable for class-wide, systemic litigation.
Whether a class action alleging systemic, state-wide failure to provide any meaningful legal representation to indigent defendants states a claim distinct from, and not barred by, the case-specific ineffective-assistance-of-counsel framework of Strickland v. Washington.