Uttecht v. Brown
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, arguing in part that the state trial judge had improperly dismissed a juror without finding that the juror's views on the death penalty would impair his ability to follow the law. The district denied his petition.
The Ninth Circuit Court of Appeals reversed, finding that the judge's dismissal of the juror violated clear Supreme Court precedent, and that the improper dismissal automatically prejudiced Brown, resulting in the invalidity of his death sentence.
Question Presented:
In Wainwright v. Witt, 469 U.S. 412 (1985), and Darden v. Wainwright, 447 U.S. 168 (1986), this Court held that a state trial judge may, without setting forth any explicit findings or conclusions, remove a juror for cause when the judge determines the juror's views on the death penalty would substantially impair his or her ability to follow the law and perform the duties of a juror. The Court further held that a federal habeas court reviewing the decision to remove must defer to the trial judge's ability to observe the juror's demeanor and credibility, and apply the statutory presumption of correctness to the judge's implicit factual determination of the juror's substantial impairment.
Did the Ninth Circuit err by not deferring to the trial judge's observations 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 law?
