Murphy v. Florida
421 U.S. 794 (1975)
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Rule of Law:
A juror's exposure to news accounts of a defendant's prior criminal convictions does not, by itself, presumptively deprive the defendant of their due process right to a fair trial. The defendant must demonstrate either that the trial setting was inherently prejudicial or that the jury selection process permitted an inference of actual prejudice.
Facts:
- Petitioner Jack Roland Murphy, known in the media as “Murph the Surf,” was notorious for his 1964 theft of the Star of India sapphire.
- In January 1968, a home in Miami Beach, Florida was robbed.
- Murphy and three others were apprehended while fleeing the scene of this robbery.
- Murphy's arrest and the charges against him received extensive press coverage due to his notoriety.
- Between his arrest for the robbery and the trial, Murphy was indicted for two murders in another county and for a federal securities crime.
- Murphy was subsequently convicted of one of the murders and pleaded guilty to the federal charge, events which also drew significant media attention.
Procedural Posture:
- Jack Murphy was charged in the Dade County, Florida, Criminal Court with robbery-related offenses.
- The trial court denied Murphy's motions for a change of venue and to dismiss the chosen jurors based on prejudicial pretrial publicity.
- Murphy was convicted by a jury in the state trial court.
- Murphy's conviction was affirmed on appeal through the Florida state court system.
- Murphy filed a petition for a writ of habeas corpus in the U.S. District Court for the Southern District of Florida, which was denied.
- The U.S. Court of Appeals for the Fifth Circuit affirmed the District Court's denial of relief.
- The U.S. Supreme Court granted certiorari.
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Issue:
Does a juror's exposure to news accounts of a defendant's prior convictions, by itself, presumptively deprive the defendant of a fair trial under the Due Process Clause?
Opinions:
Majority - Mr. Justice Marshall
No. A juror's mere knowledge of a defendant's prior convictions does not, by itself, create a presumption of prejudice that violates the Due Process Clause. The constitutional standard requires a panel of impartial jurors, not jurors who are completely ignorant of the facts. A defendant must show either that the trial setting was inherently prejudicial due to a pervasive, inflammatory media atmosphere, as seen in cases like Sheppard and Estes, or that the jury selection process revealed actual, insurmountable prejudice on the part of the jurors. In this case, the publicity was largely factual and had subsided months before the trial, and the voir dire process did not demonstrate that the seated jurors held a partiality that could not be laid aside.
Dissenting - Mr. Justice Brennan
Yes. The defendant was denied a fair trial because the risk that the jury was tainted by widespread publicity about his criminal background was too great. At least one seated juror admitted during voir dire that knowledge of Murphy's past convictions would dispose him to convict if Murphy presented no defense. Other jurors expressed similar difficulties in remaining impartial. The trial judge failed to take any steps to insulate the jurors from this prejudicial information, and the jurors' self-serving assurances of impartiality should be given little weight under the circumstances, consistent with the precedent set in Irvin v. Dowd.
Concurring - Mr. Chief Justice Burger
No. While the trial judge was 'woefully remiss' in failing to control pretrial publicity and discussion among jurors, the circumstances did not rise to the level of a constitutional violation of due process. Had this been a federal case, reversal would be appropriate under the Court's supervisory powers. However, for a state conviction, the standard is whether the Due Process Clause was violated, and that high threshold was not met here.
Analysis:
This decision clarifies the constitutional standard for juror prejudice due to pretrial publicity in state criminal trials. It rejects a per se rule that knowledge of a defendant's prior record automatically violates due process, distinguishing the constitutional minimum from the Court's stricter supervisory standards over federal courts. The ruling places a significant burden on the defendant to prove either inherent prejudice in the trial's atmosphere or actual prejudice in the jury box. This 'totality of the circumstances' approach makes it more difficult for well-known defendants to succeed on claims of media-induced bias, solidifying that an impartial jury is not necessarily an ignorant one.
