Patton et al. v. Yount
467 U.S. 1025 (1984)
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Rule of Law:
A presumption of prejudice arising from adverse pretrial publicity is rebuttable by the passage of a significant amount of time between the publicity and the trial. The relevant inquiry is not whether jurors remember the case, but whether the initial wave of public passion has subsided, allowing them to render an impartial verdict.
Facts:
- On April 28, 1966, the body of 18-year-old Pamela Rimer was found in Clearfield County, Pennsylvania.
- The next day, Jon Yount, Rimer's former high school mathematics teacher, gave oral and written confessions to the police.
- Yount's confessions were read at his arraignment and, along with other case details, were the subject of intense and widespread media coverage prior to his first trial in 1966.
- After Yount's first conviction was overturned, four years passed before his second trial began in 1970.
- During this four-year interval, media coverage of the case was sparse, averaging less than one article per month, and was primarily factual and non-inflammatory.
- News coverage during the jury selection for the second trial focused on the procedural aspects of the selection process itself, not on the substantive details of the crime or Yount's prior conviction and confession.
Procedural Posture:
- In 1966, Jon Yount was convicted of first-degree murder and rape in a Pennsylvania state trial court and sentenced to life imprisonment.
- On direct appeal, the Pennsylvania Supreme Court reversed the conviction because Yount's confession was obtained in violation of his Miranda rights and remanded the case for a new trial.
- In 1970, Yount was convicted of first-degree murder in his second trial after the trial court denied his motions for a change of venue.
- The Pennsylvania Supreme Court affirmed the second conviction.
- Yount filed a petition for a writ of habeas corpus in the U.S. District Court, which found the jury was impartial and denied the petition.
- The U.S. Court of Appeals for the Third Circuit reversed, holding that pretrial publicity had created a presumption of prejudice and made a fair trial impossible.
- The U.S. Supreme Court granted certiorari to review the decision of the Court of Appeals.
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Issue:
Does extensive and prejudicial pretrial publicity, which primarily occurred four years before a defendant's second trial, create a presumption of prejudice that violates the defendant's Sixth Amendment right to an impartial jury?
Opinions:
Majority - Justice Powell
No. The extensive pretrial publicity did not create a presumption of prejudice that violated the defendant's Sixth Amendment right because the four-year passage of time between the initial inflammatory publicity and the second trial sufficiently mitigated its prejudicial effects. The Court distinguished this case from Irvin v. Dowd, where a 'huge wave of public passion' occurred immediately before trial. Here, the publicity preceding the second trial was not a 'barrage of inflammatory' articles, and the voir dire testimony indicated that community sentiment had softened. The Court held that the relevant question is not whether jurors remember the case, but whether they have such fixed opinions that they cannot be impartial. Furthermore, a state trial court's finding on an individual juror's impartiality is a determination of historical fact entitled to a presumption of correctness under 28 U.S.C. § 2254(d), as the trial judge is best positioned to assess a juror's credibility and demeanor.
Dissenting - Justice Stevens
Yes. The pretrial publicity created a presumption of prejudice because the initial coverage was so pervasive and detailed—including Yount's confession, prior conviction, and a rape charge—that the passage of time could not erase its impact on a small rural community. The dissent argued that the voir dire record demonstrated overwhelming community prejudice, with 126 of 163 veniremen admitting they held an opinion. Several seated jurors, notably Juror Hrin, stated they had an opinion and would require evidence to change it, which unconstitutionally shifts the burden of proof to the defendant. The dissent contended that a juror's qualification is a mixed question of law and fact requiring independent federal review, not deference to the state trial court's finding.
Analysis:
This decision significantly refines the Sixth Amendment impartial jury analysis established in Irvin v. Dowd by emphasizing the curative effect of time. It establishes that the mere fact that a community remembers a notorious case does not, by itself, prove jury prejudice if a sufficient period has passed to cool public passions. The holding also strengthens the finality of state court convictions by classifying a trial judge's determination of individual juror impartiality as a finding of 'historical fact' deserving special deference on federal habeas review. This makes it substantially more difficult for defendants to later challenge juror bias, shifting the focus from the content of old news reports to the jurors' state of mind at the time of trial.
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