Two April 18 Supreme Court decisions provide both a ray of hope for condemned prisoners — the few who may be innocent as well as the many who are murderers — and a window into the byzantine maze of technicalities that death row law has become.

So byzantine is the law that sometimes even well-respected newspapers cannot agree on which way the Court is headed. In front-page stories the day after the rulings, The Washington Post explained that the Court had "curtailed the power of federal judges to override state court decisions against death row prisoners." The New York Times, on the other hand, said the Court had determined that "federal judges still have a significant role to play in reviewing the quality of justice administered by the states."

There is truth in both perspectives. But most death penalty critics and defense lawyers were, on balance, pleased. The Court made it clear that lower federal courts still can, and sometimes should, overturn state convictions and sentences. The Justices also set an example for lower court judges by finding — for the first time in the Court’s history — that a court-appointed defense lawyer had performed so badly as to violate the defendant’s long-recognized, but rarely enforced, Constitutional right to effective assistance of counsel.

The immediate effect of the rulings was to give reprieves to two murderers on Virginia’s death row, the first (Terry Williams) because his court-appointed lawyers had botched his sentencing hearing, and the second (Michael Williams) because one of his court-appointed lawyers had not botched his appeal. (The cases, and Terry and Michael Williams, are unrelated.)

Inconsistent? Not if you examine the two cases through the peculiar prism of death penalty law, which befuddles both state prisoners who want federal tickets off of death row and state officials who want to get on with the executions.

In 1985, Terry Williams used a mattock to kill a man who had refused to lend him money, and stole $3 from his victim’s wallet. Williams later confessed, and a jury convicted him of robbery and capital murder. At the sentencing hearing, the prosecution detailed his lifelong history of crime, which — in the past few months alone — had included savagely beating an elderly woman, setting fire to a home, stabbing a man during a robbery, setting fire to the city jail, and stealing two cars. Williams’ court-appointed defense lawyers responded by lamely conceding that it was hard to find a reason not to execute him. (The best they could do was to put the defendant’s mother and two neighbors on the stand to say that he had been a "nice boy.") The jury recommended a death sentence, the trial judge imposed it, and the Virginia Supreme Court (as usual) affirmed it.

In a second, subsequent state appeal, called a petition for habeas corpus, a new court-appointed lawyer stressed that Terry Williams’ trial counsel had failed to put important mitigating evidence before the jury during the sentencing hearing: The mildly retarded defendant had had a nightmarish childhood of beatings, abuse, neglect, alcoholism, and squalor. The same state circuit judge who had sentenced Williams to die now found that his trial counsel had done such a bad job as to warrant a new sentencing hearing. But the Virginia Supreme Court disagreed, saying the new mitigating evidence would have made little difference.

Then came the federal habeas corpus appeal. Virtually all death row inmates and many other state prisoners file such appeals in federal district court, only to encounter a gauntlet of procedural barriers erected by the U.S. Supreme Court and Congress to limit federal judges’ second-guessing of state judges and juries.

A federal district judge ruled for Williams, holding that the state circuit court had been right and the Virginia Supreme Court wrong. But then the famously conservative 4th U.S. Circuit Court of Appeals, in Richmond, reversed that decision on the grounds that a 1996 act of Congress had barred federal courts from granting habeas corpus petitions unless the final state ruling against the inmate was not merely wrong but so far off-base that "reasonable jurists would all agree it is unreasonable."

Had the U.S. Supreme Court adopted this view, it would have been the end of the line not only for Terry Williams but also for virtually all state prisoners who file federal habeas petitions, including those who have some evidence suggesting that they may be innocent. That’s why this was the most important case in years for death row inmates.

The bad news for inmates was that the Justices held, by a 5-4 vote, that the 1996 law bars federal judges from granting state prisoners’ habeas corpus petitions unless the final state court ruling is not merely "incorrect" as a matter of law but so egregiously incorrect as to be "objectively unreasonable." The good news was that all nine Justices voted to keep federal habeas corpus alive by rejecting the 4th Circuit’s interpretation of the 1996 law. And six Justices voted to grant Terry Williams a new trial, in what amounted to the first Supreme Court decision ever finding a particular defense lawyer so ineffective as to violate the Constitution.

So to recap: Williams won his appeal in state circuit court, which was reversed by the state supreme court, which was then reversed by federal district court, which was in turn reversed by the federal appeals court, which was itself reversed — this time with finality — by the U.S. Supreme Court. Small wonder that so few reporters noticed the importance of the decision in providing ammunition for other prisoners to argue in the future that their convictions or sentences should be set aside because their own lawyers were as inept as Terry Williams’.

This decision thus contains two important holdings. The first is that "habeas lives," and the second is that "the right to effective assistance of counsel has teeth," in the words of Stephen B. Bright, a leading critic of the death penalty and the director of the Southern Center for Human Rights in Atlanta. Coming at a time when many lower courts have come close to finding any lawyer good enough for criminal defendants if he or she has "a bar card and a pulse" (as Bright puts it), this may portend a change in direction.

The decision in the case of Michael Williams — who was less than two hours from execution when the Justices took up his appeal last Oct. 28 — may help other prisoners get their appeals past another technical barrier raised by the 1996 law. In 1993, Williams and an accomplice robbed a married couple, tied them up, raped the woman, set fire to their house, and murdered them, using a pistol that Michael Williams had stolen during a quadruple murder and robbery two months earlier. The jury convicted Williams of capital murder, robbery, abduction, and rape and recommended the death penalty, which the trial judge imposed and the Virginia Supreme Court affirmed. The same court later rejected a state habeas corpus appeal prepared by a court-appointed lawyer.

But yet another court-appointed lawyer, seeking grounds for a federal habeas corpus appeal, discovered that both the jury forewoman and one of the prosecutors had failed to disclose that the forewoman was a former client of the prosecutor’s and the former wife of a key prosecution witness. The new lawyer sought an evidentiary hearing in the hope of showing that this had tainted the fairness of the trial and sentencing. The 4th Circuit refused the hearing on the grounds that the prisoner’s previous lawyer had not been diligent enough in investigating the jurors’ backgrounds during the state court habeas appeal and, therefore, had run afoul of the 1996 law by "fail[ing] to develop" the juror-bias claim in state court.

Again the Justices reversed the 4th Circuit, this time unanimously, by holding that the delay in disclosing the forewoman’s background had been the fault of the forewoman and of the prosecutor, and showed no lack of diligence on the part of the defendant’s previous lawyer. The flip side of this analysis is, of course, that if a prisoner’s court-appointed lawyer makes a procedural error, not at the trial stage, but during a state habeas corpus appeal, the doors of the federal courts slam shut.

Why should matters of life and death turn on such distinctions as these? The nub of it, in the Court’s view, is that the Constitution guarantees effective assistance of counsel — even to those rare defendants with plausible claims of innocence — only during their trials, sentencing hearings, and initial appeals. That’s pretty rough justice. But not quite as rough as death penalty critics and defense lawyers had feared it might become.