Bell v. Cone, 535 U.S. 685 (2002), was a Supreme Court of the United States case that upheld a death sentence despite the defendant's argument that he should not be sentenced to death because he was suffering from drug-induced psychosis when he committed the crimes. Cone also argued that he was denied effective assistance of counsel because his attorney failed to present sufficient mitigating evidence during the sentencing phase of his trial and that his attorney inappropriately waived his final argument during the sentencing phase. In an 8–1 opinion written by Chief Justice William Rehnquist, the United States Supreme Court denied Cone's petition for a writ of habeas corpus. The Court held that the actions taken by Cone's attorney during the sentencing phase were "tactical decisions" and that the state courts that denied Cone's appeals did not unreasonably apply clearly established law. Justice John Paul Stevens wrote a dissenting opinion in which he argued that Cone was denied effective assistance of counsel because his attorney failed to "subject the prosecution's case to meaningful adversarial testing." Commentators have noted that Bell v. Cone is significant because it clarified the standards that should be used when determining ineffective assistance of counsel claims. Other commentators have suggested that the Court's ruling has made it more difficult for state prisoners to receive habeas relief in federal court. After several additional appeals, the United States Supreme Court ruled in Cone v. Bell (2009) that Cone should receive a new hearing in federal trial court to determine whether the prosecution's failure to disclose evidence violated Cone's rights to due process under Brady v. Maryland. In 2016, Gary Cone died from natural causes while still sitting on Tennessee's death row. Background In 1982, Gary Cone was convicted and sentenced to death for a crime spree that included the robbery of a jewelry store, a police pursuit, and the murder of an elderly couple. At trial, Cone's attorney argued that he was not guilty by reason of insanity, and several experts testified that Cone suffered from a long history of drug abuse and post traumatic stress disorder resulting from his military service during the Vietnam War. According to one expert, Cone's long-term drug abuse caused hallucinations and paranoia that "affected respondent's mental capacity and ability to obey the law." The jury rejected Cone's insanity defense and found him guilty on all counts. At a sentencing hearing, Cone's attorney