October Term 2013 · Docket 12-414

Does a silent record prove ineffective assistance of counsel?

The dispute centers on whether a court can find ineffective assistance of counsel based solely on a silent record.

Official caption
Burt v. Titlow
Latest argument session
Latest official Court activity
Latest verified event
Argued
Sources analyzed through
Official Transcript

Verified source milestones

  1. — An official oral-argument transcript was verified.
  2. — An official oral-argument transcript was verified.

The arguments, in order

This case may have been argued more than once. Each entry below uses that session's official transcript. Later arguments do not erase earlier ones.

  1. Argument 1 ·

    What happened at the argument

    the side that brought the case's advocate stated that the Michigan Court of Appeals erred in creating an end-run around Strickland.

    the side that brought the case's advocate argued that a defendant's professed innocence does not automatically prove effective assistance.

    the opposing side's advocate noted that the lower court found the submitted materials sufficient to justify a hearing.

    Justice Kagan questioned the lower court's reasoning regarding a defendant's refusal to plead guilty.

    Read the official transcript for this argument · Official argument details

    Sources used for this argument breakdown

A citizen's guide to the whole case

What this case is about

This case involves a prisoner challenging his conviction. The core issue is the standard for proving ineffective assistance of counsel in habeas corpus proceedings.

Official sources for this section

How the case got here

The Supreme Court heard oral argument in this case on October 8, 2013.

Official sources for this section

What each side wants

the side that brought the case wants the Supreme Court to reject the lower court's reliance on a silent record to prove ineffective assistance.

the opposing side wants the Supreme Court to uphold the lower court's finding that the record supports the ineffective assistance claim.

Official sources for this section

What each side says

the side that brought the case argues that no court has ever allowed a presumption of ineffective assistance based solely on a silent record.

the opposing side argues that the lower court correctly found the materials sufficient to justify a hearing on ineffective assistance.

Official sources for this section

What the justices asked

Justice Alito asked if the final sentence fell within Michigan guidelines.

Justice Breyer asked for clarification on habeas corpus law principles.

Official sources for this section

Why it matters

This case defines the evidentiary standard for proving ineffective assistance of counsel. It clarifies how courts must evaluate attorney performance in habeas proceedings. The outcome impacts the rights of prisoners seeking post-conviction relief.

Official sources for this section

What happens next

This article currently covers the argument record. Use the official docket link for later case activity.

Official sources for this section

Official Court provenance

Official docket and case history · Official Supreme Court oral-argument detail page

Title and summary sources

Revision history

  1. Revision 1 · Official Transcript ·

    Correction: Rewritten to the concise citizen-facing editorial standard.

  2. Revision 2 · Official Transcript ·

    Correction: Migrated to the dated official Court activity contract without model use.

Download this sanitized case as JSON