Carlos Javier Figueroa v. United States
In McCoy v. Louisiana, 584 U.S. 414 (2018), this Court held that (1) the Sixth Amendment guarantees a criminal defendant the autonomy to decide the objective of his defense, including maintaining innocence at trial despite overwhelming evidence of guilt; and (2) counsel who overrides that decision by conceding defendant's guilt commits structural error requiring reversal. This Court rejected counsel's justification that he conceded defendant's guilt because he believed the innocence claim was false or incredible in light of the evidence, holding that counsel's belief in his client's guilt does not authorize counsel to override a defendant's choice to pursue innocence at trial.
The question presented is: Whether counsel violates the Sixth Amendment when counsel overrides the defendant's express request to call a witness he identifies as essential to his innocence defense, on the ground that the witness would commit perjury if called -- even though counsel hadn't spoken to the witness -- because counsel believed the defendant was guilty.
Whether counsel violates the Sixth Amendment when counsel overrides the defendant's express request to call a witness he identifies as essential to his innocence defense, on the ground that the witness would commit perjury if called -even though counsel hadn't spoken to the witness -because counsel believed the defendant was guilty