Turner v. Murray
476 U.S. 28, 106 S.Ct. 1683, 90 L.Ed.2d 27 (1986)
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Rule of Law:
A defendant in a capital case involving an interracial crime is constitutionally entitled, upon request, to have prospective jurors informed of the race of the victim and questioned on the issue of racial bias during voir dire.
Facts:
- Willie Lloyd Turner, a Black man, entered a jewelry store in Franklin, Virginia, armed with a sawed-off shotgun.
- Turner demanded jewelry and money from the proprietor, W. Jack Smith, Jr., a white man.
- Smith complied but triggered a silent alarm, which brought police officer Alan Bain to the store.
- Turner disarmed Officer Bain and, upon hearing an approaching siren, shot Smith in the head, incapacitating him.
- Turner then declared he was going to kill Smith for "snitching" and fired two more shots into Smith's chest, killing him.
- Officer Bain was able to disarm and arrest Turner at the scene.
Procedural Posture:
- A grand jury in Southampton County, Virginia, indicted Willie Lloyd Turner for capital murder.
- The trial was moved to Northampton County on a motion for a change of venue.
- During jury selection (voir dire), Turner's counsel submitted a proposed question asking prospective jurors if the interracial nature of the crime would prejudice them, but the trial judge refused to ask it.
- The jury convicted Turner and, after a separate hearing, recommended the death sentence, which the judge imposed.
- Turner, as appellant, appealed to the Virginia Supreme Court, which, as appellee, affirmed the conviction and sentence.
- Turner filed a petition for a writ of habeas corpus in the U.S. District Court for the Eastern District of Virginia, which denied the petition.
- Turner, as appellant, appealed to the U.S. Court of Appeals for the Fourth Circuit, which affirmed the District Court's denial of relief against the appellee, the warden.
- The U.S. Supreme Court granted certiorari to review the decision of the Court of Appeals.
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Issue:
Does a trial judge's refusal to question prospective jurors on racial prejudice, when requested by a defendant in a capital case involving an interracial crime, violate the defendant's constitutional right to an impartial jury?
Opinions:
Majority - Justice White
Yes, the refusal to question prospective jurors on racial prejudice in a capital case involving an interracial crime violates the defendant's constitutional right to an impartial jury, specifically at the sentencing phase. The wide discretion given to a jury in a capital sentencing hearing creates a unique opportunity for racial prejudice to operate undetected. This risk, combined with the finality of the death penalty, makes the potential for racial bias constitutionally unacceptable. The rule from Ristaino v. Ross, which requires special circumstances beyond the mere fact of an interracial crime, does not apply to the sentencing phase of a capital trial due to these factors. However, because the jury's discretion at the guilt phase is no different from a noncapital trial, the conviction itself is not constitutionally infirm.
Dissenting - Justice Powell
No, the trial judge's refusal does not violate the defendant's constitutional rights. The Court's decision creates an unwise per se rule based on an unjustifiable presumption that jurors in capital cases are racially biased, contrary to precedent set in Ristaino. The established rule, requiring a showing that racial issues are 'inextricably bound up with the conduct of the trial,' is sufficient to protect defendants' rights. The procedural and substantive safeguards that circumscribe a capital jury's sentencing decision are adequate to prevent arbitrary or biased outcomes, and there is no evidence of racial bias in this particular case.
Concurring-in-part-and-dissenting-in-part - Justice Brennan
Yes, the refusal to question jurors about racial bias was a constitutional error, but the Court is wrong to limit its remedy to only the sentencing phase. The risk of racial bias tainting the jury process is equally present at the guilt phase of a capital trial, as subconscious fears and prejudices can influence a juror's assessment of witness credibility and other discretionary decisions that lead to a conviction. To suggest that a jury could be unacceptably biased for sentencing but acceptably fair for conviction is illogical. The constitutional right to an impartial jury applies to the entire trial, so the conviction, as well as the sentence, should be vacated.
Concurring-in-part-and-dissenting-in-part - Justice Marshall
Yes, the refusal was unconstitutional, and I concur in vacating the sentence but dissent from the Court's refusal to reverse the conviction. A criminal defendant should be entitled to inquire about potential racial bias whenever a case involves a violent interracial crime, regardless of whether it is a capital case. The risk of prejudice plainly outweighs the minor cost of allowing such an inquiry. It is incongruous and fundamentally unfair to acknowledge that the jury may have been biased, vacate the sentence on that basis, and yet force the petitioner to accept a conviction rendered by that same potentially biased jury.
Analysis:
This case establishes a critical, albeit narrow, exception to the rule from Ristaino v. Ross. While Ristaino held that the mere fact of an interracial crime does not create a constitutional need to question jurors about racial bias, Turner carves out a per se rule for capital cases. The decision elevates the combination of an interracial crime and a capital charge to the level of a 'special circumstance' requiring voir dire on race, but only for the sentencing phase. This bifurcation of the trial—finding a constitutional violation at sentencing but not at the guilt phase—highlights the Court's unique concern for the discretionary and final nature of the death penalty, setting a precedent that would be influential in subsequent capital jurisprudence.
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