Uttecht v. Brown

Infobox SCOTUS case
Litigants=Uttecht v. Brown
ArgueDate=April 17
ArgueYear=2007
DecideDate=June 4
DecideYear=2007
FullName=Jeffrey Uttecht, Superintendent, Washington State Penitentiary, Petitioner v. Cal Coburn Brown
Docket=06-413
USVol=
USPage=
CitationNew=551 U.S. ___; 127 S.Ct. 2218
OralArgument=http://www.oyez.org/cases/2000-2009/2006/2006_06_413/argument/
Prior=
Subsequent=
Holding=The Washington state judge who presided over the trial of "Brown" properly used his discretion to excuse a potential juror who expressed equivocal views about the death penalty. 451 F. 3d 946, reversed and remanded.
SCOTUS=2006-2008
Majority=Kennedy
JoinMajority=Roberts, Scalia, Thomas, Alito
Dissent=Stevens
JoinDissent=Souter, Ginsburg, Breyer
Dissent2=Breyer
JoinDissent2=Souter
LawsApplied=

"Uttecht v. Brown", 551 U.S. ___ (2007), was a case dealing with jury selection in capital cases in which the Supreme Court of the United States held that appeals courts must defer to a trial judge’s decision on whether a potential juror would be able to overcome demur about capital punishment and be open to voting to impose a death sentence.

Background and court history

Brown was convicted of murder and sentenced to death in a Washington State Court. After his conviction was affirmed by state courts, Brown filed a petition for a writ of habeas corpus in federal district court, in which he argued in part that the state trial judge had improperly dismissed a juror without finding that the juror's views on capital punishment would impair his ability to follow the law. The district denied his petition and Brown appealed.

The 9th Circuit Court of Appeals reversed the lower court's ruling and upheld Brown's objections as valid finding that the judge's dismissal of the juror infringed upon clear Supreme Court precedent, and that said dismissal prejudiced the jury against the defendant, nullifying his death sentence.http://www.law.duke.edu/publiclaw/supremecourtonline/certgrants/2006/uttvbro]

Question

The question before the Court was whether or not the 9th Circuit Court of Appeals had made an error by not deferring to the trial judge's observations concerning a prospective juror's views on capital punishment and by not applying the statutory presumption of correctness in ruling that the state court decision to remove a juror was contrary to clearly established federal law. [http://docket.medill.northwestern.edu/archives/004257.php]

Opinion of the Supreme Court

In a 5-4 conservative-liberal split the majority found that the 9th Circuit had indeed erred when they overruled the Washington State Court's decision and invalidated Brown's death sentence. The precedents of "Wainwright v. Witt", 469 U.S. 412 (1985), and "Darden v. Wainwright", 447 U.S. 168 (1986), established that a state trial judge may, without presenting any explicit findings or conclusions, remove a juror for cause when the judge determines the juror's views on the death penalty would substantially limit his or her ability to follow the law and perform the duties of a juror. Justice Kennedy, writing for the majority, said that appeals courts must defer to a trial judge’s decision on whether a potential juror would be able to overcome qualms regarding the death penalty and be open to voting to impose execution as a sentence. [cite news |first=Linda |last=Greenhouse |authorlink= |coauthors= |title=In Steps Big and Small, Supreme Court Moved Right |url=http://www.nytimes.com/2007/07/01/washington/01scotus.html |work=New York Times |publisher= |date=2007-07-01 |accessdate=2008-10-08 ]

Dissent

The dissenting opinion, joined by Justices Ginsburg, Souter and Breyer, and written by Justice Stevens expressed concern that the decision set the disqualification bar for prospective jurors too low and in effect could cause juries to be more likely to vote for a death sentence.

References