Wainwright v. Witt
469 U.S. 412 (1985)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The proper standard for determining when a prospective juror may be excluded for cause because of their views on capital punishment is whether the juror's views would prevent or substantially impair the performance of their duties as a juror in accordance with their instructions and their oath.
Facts:
- Johnny Paul Witt and an accomplice had previously discussed killing a human and had stalked people as prey.
- While hunting, Witt's accomplice struck an 11-year-old boy, who was riding a bicycle, on the head with a star bit from a drill.
- Witt and his accomplice gagged the stunned boy and placed him in the trunk of Witt's car.
- They drove to a deserted grove, where upon opening the trunk, they discovered the boy had died by suffocating from the gag.
- Witt and his accomplice then committed various sexual and violent acts on the boy's body before digging a grave and burying it.
Procedural Posture:
- Johnny Paul Witt was convicted of first-degree murder in a Florida state trial court.
- During jury selection (voir dire), prospective juror Colby stated she was afraid her personal beliefs against the death penalty would 'interfere' with judging guilt or innocence.
- The prosecutor's motion to excuse Colby for cause was granted by the trial judge without an objection from defense counsel.
- Following the jury's recommendation, the trial judge sentenced Witt to death.
- Witt (appellant) appealed to the Florida Supreme Court, which affirmed the conviction and sentence against the State of Florida (appellee).
- After state postconviction relief was denied, Witt filed a petition for a writ of habeas corpus in the U.S. District Court for the Middle District of Florida, which was denied.
- Witt (appellant) appealed to the U.S. Court of Appeals for the Eleventh Circuit, which reversed the district court and granted the writ, finding that juror Colby was improperly excused.
- The State of Florida, through its representative Wainwright (petitioner), was granted a writ of certiorari by the U.S. Supreme Court.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Is the standard for determining whether a prospective juror may be excluded for cause because of their views on capital punishment whether those views would 'prevent or substantially impair the performance of his duties as a juror in accordance with his instructions and his oath'?
Opinions:
Majority - Justice Rehnquist
Yes. The proper standard for excluding a juror for cause based on their views on capital punishment is whether those views would 'prevent or substantially impair the performance of his duties as a juror in accordance with his instructions and his oath.' The Court abandons the rigid 'unmistakably clear' and 'automatic' opposition language from Witherspoon v. Illinois, deeming it dicta and unsuited for modern capital sentencing schemes that involve guided discretion. The Court adopts the more flexible standard from Adams v. Texas, which does not require a juror’s bias to be proven with 'unmistakable clarity.' Furthermore, a trial judge's determination of juror bias is a finding of fact entitled to a presumption of correctness under 28 U.S.C. § 2254(d) on federal habeas review. Because a trial judge is in a superior position to assess a juror's demeanor and credibility, their determination of bias must be given deference. In this case, prospective juror Colby's statements that she was afraid her beliefs would 'interfere' with her duties were sufficient to support the trial judge's decision to excuse her for cause.
Dissenting - Justice Brennan
No. The Court's decision abandons the strict and necessary protections established in Witherspoon, which required the State to show with unmistakable clarity that a juror was unable to be impartial. The Witherspoon standard correctly allocated the risk of ambiguity to the State to protect a capital defendant's Sixth Amendment right to an impartial jury drawn from a fair cross-section of the community, guarding against juries 'uncommonly willing to condemn a man to die.' By adopting a more lenient standard and treating death-qualification like any other form of bias, the majority ignores the systemic risk of creating juries skewed in favor of the prosecution. This decision unconstitutionally shifts the risk of a biased jury onto the defendant and debases the fundamental right to a jury that represents the conscience of the community.
Concurring - Justice Stevens
Yes, the judgment to reverse the Court of Appeals is correct, but for a narrower reason than the majority provides. The dispositive fact in this case is that defense counsel failed to object to the exclusion of juror Colby or attempt to rehabilitate her. This silence, especially when contrasted with counsel's objections to the removal of other prospective jurors, suggests a deliberate tactical decision not to have Colby on the jury. Given this context, the state's failure to make a more thorough record as required by Adams v. Texas does not constitute a fundamental error that would invalidate the death sentence. The Court's broader discussion of the Witherspoon standard is unnecessary to resolve this specific case.
Analysis:
Wainwright v. Witt significantly altered the landscape of jury selection in capital cases by lowering the standard for juror exclusion. By formally replacing the stringent Witherspoon standard with the more deferential 'prevent or substantially impair' test from Adams, the Court made it substantially easier for prosecutors to remove jurors who express reservations about the death penalty. This decision, coupled with its holding that a trial judge's bias determination is a factual finding entitled to deference on habeas review, severely limits a capital defendant's ability to challenge juror exclusions. The ruling reflects a shift in balance, prioritizing the state's interest in empaneling a jury that can impose a death sentence over the defendant's Sixth Amendment interest in a jury drawn from the broadest possible cross-section of the community.
Unlock the full brief for Wainwright v. Witt