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Patton v. Yount

Supreme Court of the United States · 1984 · Civil Procedure

Civil Procedureimpartial jurypretrial publicityhabeas corpusvoir direSixth Amendmentimpartial jurypretrial publicity

Facts

Yount's first murder conviction was reversed, and he was retried four years after the crime and first trial. Before the second trial, he moved repeatedly for a change of venue, arguing that publicity in Clearfield County had made an impartial jury impossible, but the trial court denied those motions after a lengthy 10-day voir dire. The state courts found that publicity and public interest had greatly diminished between the two trials and that the seated jurors had no fixed opinions preventing impartiality. On federal habeas, the court of appeals concluded that the publicity and voir dire responses showed the jury was not impartial.

Issue

Whether the state trial court erred in finding that Yount's second trial jury was impartial despite prior publicity, and whether the seating of certain challenged jurors required federal habeas relief. More specifically, the question was what deference federal habeas courts owe to state-court determinations of jury and juror impartiality.

Rule

The relevant question in a pretrial-publicity case is whether the jurors who sat had such fixed opinions that they could not judge impartially the defendant's guilt. A trial court's finding that the jury as a whole was impartial may be overturned only for manifest error, and in federal habeas proceedings the question whether an individual juror could set aside any opinion and decide the case on the evidence is a question of historical fact entitled to the statutory presumption of correctness if fairly supported by the record.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Tulsa, Oklahoma, Daniel Mercer was retried for arson four years after his first conviction was vacated. Local coverage had been intense at the time of the fire, but in the 18 months before retrial the newspapers ran only brief scheduling notices, and after an eight-day voir dire the judge excused veniremembers who still said they had fixed views about Daniel's guilt.

On federal habeas, Daniel argues that the community's earlier outrage made an impartial jury impossible. What is the strongest response under the governing rule?

Explanation. The controlling inquiry is not whether the community once reacted strongly, but whether the jurors who actually sat had fixed opinions they could not lay aside. The majority stressed that passage of time and diminished, largely factual publicity can rebut any earlier presumption of prejudice. A trial court's finding that the jury as a whole was impartial is reviewed only for manifest error.