WHITE v. WOODALL

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Case Basics
Docket No. 
12-794
Petitioner 
Randy White, Warden
Respondent 
Robert Keith Woodall
Advocates
(for the petitioner)
(for the respondent (appointed by the Court))
Term:
Facts of the Case 

On January 25, 1997, a sixteen-year-old girl was kidnapped, murdered, and raped. After an investigation, the police arrested Robert Woodall, who subsequently pled guilty to capital murder, capital kidnapping, and first-degree rape. At trial, Woodall invoked his Fifth Amendment right to avoid self-incrimination and declined to testify, and so he asked the judge to instruct the jury not to make any adverse inferences from that decision. The judge refused to issue the “no adverse inference” instruction and stated that, by entering a guilty plea, Woodall waived his right to be free from self-incrimination. The jury found Woodall guilty on all charges and the judge sentenced him to the death penalty and two subsequent life sentences.

Woodall appealed to the Kentucky Supreme Court, which affirmed both Woodall’s conviction and sentence. In 2006, Woodall filed a habeus corpus petition in federal court, and that court held that the trial court violated Woodall’s Fifth Amendment right when it refused to offer the requested jury instruction. In addition, that court also held that Woodall’s Fifth, Eighth, and Fourteenth Amendment rights were violated when the trial court allowed the state to dismiss an African-American juror without a mandatory hearing for cause. On appeal, the U.S. Court of Appeals for the Sixth Circuit affirmed the district court’s decision on the issue of self-incrimination but did not address the other issues.

Question 

(1) Did the trial court violate Woodall’s Fifth Amendment rights when it refused to provide a “no adverse inference” instruction to the jury in a capital punishment case in which the defendant has pled guilty?

(2) Was the trial court’s failure to provide a “no adverse inference” instruction a harmless error in light of the overwhelming evidence of guilt that resulted in a guilty plea?

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WHITE v. WOODALL. The Oyez Project at IIT Chicago-Kent College of Law. 18 April 2014. <http://www.oyez.org/cases/2010-2019/2013/2013_12_794>.
WHITE v. WOODALL, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2010-2019/2013/2013_12_794 (last visited April 18, 2014).
"WHITE v. WOODALL," The Oyez Project at IIT Chicago-Kent College of Law, accessed April 18, 2014, http://www.oyez.org/cases/2010-2019/2013/2013_12_794.