The "Double-Edged" Dilemma: The Eleventh Circuit's Devaluation of Mental Health Mitigators in Evans v. Secretary, Department of Corrections

Abstract

In Evans v. Secretary, Department of Corrections, the United States Court of Appeals for the Eleventh Circuit denied habeas corpus relief to a death row inmate who claimed that ineffective assistance of counsel prejudiced his death sentence hearing. Despite the defense counsel’s omission of evidence suggesting that the inmate suffered from various mental disabilities, the court resolved that such evidence would not have affected the jury’s ultimate recommendation of the death sentence because some of the evidence was stigmatized. This standard creates a burden that is far too great for individuals facing the death penalty and significantly minimizes the mitigating value of mental disabilities. The Eleventh Circuit should have adopted the “probing and fact-specific” analysis proposed by Judge Martin in her dissenting opinion, which examines whether a lower court properly gauged the value of the mental health evidence. This analysis would better protect prisoners suffering from mental disorders from undeserved death sentences.