The Oyez Project: Criminal Procedure Issues - Extra-Legal Jury Influences Decisions

Adams v. Texas

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Alcorta v. Texas

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Arthur Andersen LLP v. United States

Did the jury instructions in the Arthur Andersen trial properly convey the elements of a "corrupt persuasion" conviction under federal document-handling law?

No. In a unanimous opinion delivered by Chief Justice William H. Rehnquist, the Court held that the jury instructions failed to convey that the federal document law required a "consciousness of wrongdoing" for conviction. There was nothing inherently corrupt in ordering employees to destroy documents, even if the aim was to keep the documents from the government. Thus, contrary to what the jurors had been told, Andersen could be convicted only if the persuaders were shown to be conscious that they were behaving corruptly.

Beck v. Washington

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Buchanan v. Kentucky

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Bumper v. North Carolina

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California v. Brown

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Carella v. California

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Chandler v. Florida

Does allowing radio, television, and still photographic coverage of a criminal trial for public broadcast violate the accused's right to a fair trial as guaranteed by the Sixth and Fourteenth Amendments?

The Court found no constitutional violation in this case. Chief Justice Burger first denied Chandler's and Granger's claim that the Court's holding in Estes v. Texas (1964) regarded television cameras in the courtroom as offensive to due process. State experimentation with "evolving technology" in the courtroom, as long as it does not infringe on "fundamental guarantees" of the accused, is consistent with the Constitution. Furthermore, Florida's policy was implemented with strict guidelines intended to protect the right of a defendant to a fair trial. For example, the state required its courts to protect certain witnesses from the "glare of publicity" and to hear and consider arguments from a defendant who feels that electronic coverage may bias the jury.

Connecticut v. Johnson

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Costello v. United States

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Cupp v. Naughten

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Darcy v. Handy

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Delli Paoli v. United States

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Donnelly v. Dechristoforo

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Estelle v. Williams

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Estelle, Warden v. Mcguire

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Estes v. Texas

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Francis v. Franklin

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Frazier v. Cupp

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Gannett Co. v. DePasquale

Did the press and members of the public have a constitutional right under the Sixth Amendment to attend the trial?

The Court held that members of the public had no right to attend criminal trials under the Sixth and Fourteenth Amendments. The Court noted that judges had "an affirmative constitutional duty" to minimize the effects of prejudicial pretrial publicity, and that closure of pretrial proceedings was an effective method to do so. The Court found that the Sixth Amendment, while granting defendants the right to a public trial, did not imply a public right of access to trials. The Court added that since the suppression of the transcript was only temporary, no violation of the First Amendment had occurred.

Gibson v. Lockheed Aircraft Co.

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Giles v. Maryland

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Gold v. United States

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Gray v. Mississippi

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Groppi v. Wisconsin

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Ham v. South Carolina

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Henderson v. Kibbe

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Holbrook v. Flynn

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Holland v. Illinois

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Irvin v. Dowd

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James v. Kentucky

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Jenkins v. United States

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Johnson v. Bennett

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Kelly v. South Carolina

Did the state trial court err in holding Simmons v. South Carolina, 512 U.S. 154 inapposite in the death sentence proceeding of William Kelly?

Yes. In a 5-4 opinion delivered by Justice David H. Souter, the Court held that Kelly was entitled to a jury instruction that he would be ineligible for parole under a life sentence. The Court reasoned that the Simons rule was applicable because under South Carolina's sentencing scheme, although a defendant charged with murder carrying the possibility of a death sentence could receive a sentence less than life imprisonment, a jury's only alternatives were to recommend death or life without parole, if the jury found the existence of an aggravating circumstance. Moreover, the Court found that the assertion that the defendant's future dangerousness was not at issue was unsupportable on the record.

Kentucky v. Whorton

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Koehler v. Engle

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Lockhart v. McCree

During a capital trial does the Constitution prohibit the removal of prospective jurors whose opposition to the death penalty is so strong that it would prevent or substantially impair the performance of their duties at the sentencing phase of the trial?

The Court found that excluding people who are unwilling under any circumstances to impose the death penalty during sentencing did not violate a defendant's Sixth and Fourteenth Amendment rights. Justice Rehnquist argued that the state has a legitimate interest to impanel jurors who "can properly and impartially apply the law to the facts of the case at both the guilt and sentencing phases of a capital trial." As long as a jury is selected from a fair cross-section of the community, is impartial, and can properly apply the law to a case's circumstances, then a defendant's constitutional right to a fair trial is protected.

Loper v. Beto

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Louie L. Wainwright, Secretary, Florida, Dept of Corrections v. Johnny Paul Witt

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Marshall v. United States

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Maxwell v. Bishop

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Mcgautha v. California

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Middleton v. McNeil

Were the instructions given to the jury in McNeil's trial sufficiently misleading to warrant the reversal of her sentence?

No. In a per curiam (unsigned) opinion, the Court ruled that the judge had provided correct instructions for three other parts of the instruction that were closely related to the error, and that, given the clarity of those instructions, the jury was unlikely to have been mislead by the four words erroneously inserted at the end. "Given three correct instructions and one contrary one, the state court did not unreasonably apply federal law when it found that there was no reasonable likelihood the jury was misled."

Miller v. Pate

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Morgan v. Illinois

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Mu'min v. Virginia

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Murphy v. Florida

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Napue v. Illinois

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Neder v. United States

Does the District Court's omission of the element of materiality from a jury instruction on tax fraud constitute harmless error? Is materiality an element of federal mail, wire, and bank fraud?

Yes and Yes. In an opinion delivered by Chef Justice William H. Rehnquist, the Court held 6-3 that under the harmless-error rule, which applies to a jury instruction that omits an element of an offense, the trial court's error did not render Neder's trial "fundamentally unfair." Thus, the error was harmless. In dissent, Justices Antonin Scalia, David H. Souter, and Ruth Bader Ginsburg argued that depriving a criminal defendant of the right to have a jury determine his commission of every element of the crime charged could not constitute a harmless error. Additionally, the Court unanimously held that materiality is an element of federal mail fraud, wire fraud, and bank fraud.

Parker v. Gladden

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Patton v. Yount

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Remmer v. United States

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Rideau v. Louisiana

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Riggins v. Nevada

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Ristaino v. Ross

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Rosales-Lopez v. United States

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Rose v. Clark

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Ross v. Oklahoma

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Sandstrom v. Montana

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Sansone v. United States

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Shafer v. S. Carolina

Did the South Carolina Supreme Court properly hold Simmons v. South Carolina inapplicable to the state's current sentencing regime?

No. In a 7-2 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that "whenever future dangerousness is at issue in a capital sentencing proceeding under South Carolina's new scheme, due process requires that the jury be informed that a life sentence carries no possibility of parole." Justice Ginsburg wrote that "[i]t is only when the jury endeavors the moral judgment whether to impose the death penalty that parole eligibility may become critical. Correspondingly, it is only at that stage that Simmons comes into play, a stage at which South Carolina law provides no third choice, no 30-year mandatory minimum, just death or life without parole." Justices Antonin Scalia and Clarence Thomas filed dissenting opinions.

Shannon v. United States

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Sheppard v. Maxwell

What threshold must be crossed before a trial is said to be so prejudicial, due to context and publicity, as to interfere with a defendant's Fifth Amendment due process right to a fair trial?

In an 8-to-1 decision the Court found that Sheppard did not receive a fair trial. Noting that although freedom of expression should be given great latitude, the Court held that it must not be so broad as to divert the trial away from its primary purpose: adjudicating both criminal and civil matters in an objective, calm, and solemn courtroom setting. The Cleveland television media's repeated broadcasts of Sheppard confessing in detail to crimes he was later charged with, the blatant and hostile trial coverage by Cleveland's radio and print media, and the physical arrangement of the courtroom itself - which facilitated collaboration between the prosecution and present media - all combined to so inflame the jurors' minds against Sheppard as to deny him a fair trial. The Court concluded that the trial judge should have either postponed the proceedings or transferred them to a different venue.

Simmons v. South Carolina

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Spencer v. Texas

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Sullivan v. Louisiana

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Taylor v. Kentucky

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Turner v. Louisiana

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Turner v. Murray

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United States v. Bishop

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United States v. Gaudin

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Victor v. Nebraska

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Weeks v. Angelone

Is the Constitution's due process requirement violated when a trial judge directs a capital jury's attention to a specific paragraph of a constitutionally sufficient instruction in response to a question regarding the proper consideration of mitigating circumstances?

No. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that the Constitution was not violated by the Virginia trial judge who, during a capital trial's penalty phase, directed the jury's attention to the allegedly ambiguous paragraph of the jury's instruction in response to the jury's question as to mitigating evidence. "Given that petitioner's jury was adequately instructed, and given that the trial judge responded to the jury's question by directing its attention to the precise paragraph of the constitutionally adequate instruction that answers its inquiry, the question becomes whether the Constitution requires anything more," wrote Chief Justice Rehnquist, "[w]e hold that it does not." Writing for the dissenting minority, Justice John Paul Stevens argued that "[t]he record in this case establishes, not just a 'reasonable likelihood' of jury confusion, but a virtual certainty that the jury did not realize that there were two distinct legal bases for concluding that a death sentence was not 'justified.'"

Whitney v. Florida

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Witherspoon v. Illinois

Does a state statue that provides grounds for the dismissal of any juror with "conscientious scruples" against capital punishment violate the Sixth Amendment's guarantee of an "impartial jury" and the 14th Amendment's guarantee of due process?

Yes. In an opinion delivered by Justice Potter Stewart, the Court held 6-3 that Witherspoon's death sentence was unconstitutional. The Court reasoned that a jury composed after the dismissal of all who oppose the death sentence was biased in favor the death sentence; such a jury was not impartial and thus violated the Sixth and Fourteenth Amendments. The Court held that while jurors who say they will not impose the death sentence can be dismissed, jurors who simply oppose the death sentence as a personal belief may not. Justice William Douglas, concurring, argued that it also unconstitutional to dismiss prospective jurors who say they will never impose the death sentence.

Justice Hugo Black, with whom Justices John Harlan and Byron White joined, dissented. Douglas argued that the Constitution allows the dismissal of all jurors who oppose the death penalty personally, because they will be necessarily biased against the death penalty. In a separate dissent, White argued that the Illinois legislature was allowed to exclude "those with doubts" about "one of the punishments among which the legislature sought to have them choose...."

Yates v. Evatt

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