Wainwright v. Witt
Wainwright v. Witt | |
---|---|
Case history | |
Prior | Witherspoon v. Illinois; set for reargument, 391 U.S. 510 (1968) |
Subsequent | Rehearing denied, 470 U.S. 1039 (1985) |
Holding | |
Juror can be excused from jury due to beliefs on capital punishment during the voir dire. | |
Court membership | |
| |
Case opinions | |
Majority | Rehnquist, joined by Burger, White, Blackmun, Powell, O'Connor |
Concurrence | Stevens |
Dissent | Brennan, joined by Marshall |
Laws applied | |
U.S. Const. amends. VI, XIV |
Wainwright vs. Witt, 469 U.S. 412 (1985), was a U.S. Supreme Court case concerning a criminal defendant, Johnny Paul Witt, who argued that his Sixth and Fourteenth Amendment rights were violated when he was sentenced to death for first degree murder by the state of Florida. He argued that the trial court had unconstitutionally hand-picked a jury during the voir dire process.[1] This was because certain people were excused from the jury because they admitted pre-trial, that their decision of guilty or not guilty toward capital punishment would be swayed due to personal or religious beliefs.[2]
Background
Facts
In 1974, the defendant, Johnny Paul Witt (January 13, 1943 – March 6, 1985), was tried and convicted of
Procedural history
After being convicted of first degree murder on February 21, 1974, Witt was also sentenced to the
In a previous U.S. Supreme Court case,
Opinion of the Court
The Court found that Witt's Sixth and Fourteenth Amendment rights were not violated by the voir dire process that took place before the trial began. They effectively found that the court does have a right to ask a juror to step down pretrial if in fact their beliefs do affect the verdict of the trial in any way. Witt's appeals were dismissed even before a 4th hearing took place. Witt wasn't the first person who took an appeal to Supreme Court because he was sentenced to death by a death qualified jury. For example, Knighton v. Maggio, Witherspoon v. Illinois, and Woodward v. Hutchins were cases in which all the defendants claimed their Sixth and Fourteenth Amendment rights were violated and all of their appeals were denied as well.[1] What made the Witt vs. Wainwright case so significant was the fact that the court did find that the prosecutor, during one of the exchanges over voir dire, did not properly excuse one of the jurors for the "Witherspoon claim." The juror, named Ms.Colby, stated that during the voir dire process, she thought that her judging of innocence or guilt may be affected due to the death penalty. She didn't say, however, that she would automatically vote not guilty.
- Mr. Plowman [for the State]: Now, let me ask you a question, ma'am. Do you have any religious beliefs or personal beliefs against the death penalty?
- Ms. Colby: I am afraid personally but not—Mr. Plowman: Speak up, please.
- Ms. Colby: I am afraid of being a little personal, but definitely not religious.
- Mr. Plowman: Now, would that interfere with you sitting as a juror in this case?
- Ms. Colby: I am afraid it would.
- Mr. Plowman: You are afraid it would?
- Ms. Colby: yes, sir.
- Mr. Plowman: Would it interfere with judging the guilt or innocence of the defendant in this case?
- Ms. Colby: I think so.
- Mr. Plowman: You think it would?
- Ms. Colby: I think it would.
- Mr. Plowman: Your Honor, I would move for cause at this point.
- THE COURT: All right.Step down.[3]
She was excused from the jury. The Supreme Court ruled to overlook this as evident by the denial of appeal, almost rewriting the ruling given down by
Historical context
The Supreme Court revised the standards set forth in Witherspoon with the standards provided by Wainwright v. Witt in terms of how a jury can become death qualified. "The Witt standard gave more discretion to the judge in death qualification. The judge decides whether the jurors' attitudes toward the
Conclusion
Witt appealed his sentence of capital punishment because he felt a death qualified jury violated his 6th and 14th Amendments, especially with the removal of Ms.Colby from the jury. Unfortunately for him, the standards set by Witherspoon v. Illinois (1968) did not apply to his case. Instead, his case brought new standards that ultimately shaped how a jury can be changed in a trial involving capital punishment. These standards have been researched, criticized, and even brought back to Supreme Court as evident in Lockhart v. McCree (1986) and Uttecht v. Brown (2007).[2] No matter how many appeals get brought to the Supreme Court, they still back the same standards set by Witt over 25 years ago. These standards laid down the foundations and guidelines on how we choose a death qualified jury to this day.
Witt was executed the next day, March 6, 1985.[10]
See also
- Capital punishment in Florida
- Capital punishment in the United States
- List of people executed in Florida
Notes
- ^ a b Witt v. Wainwright, 470 U.S. 1039 (1985).
- ^ a b Wainwright v. Witt, 469 U.S. 412 (1985).
- ^ a b "LOUIE L. WAINWRIGHT, SECRETARY, FLORIDA DEPARTMENT OF CORRECTIONS, PETITIONER V. JOHNNY PAUL WITT". Cornell Legal Information Institute. Retrieved November 4, 2011.
- ^ a b "Witt v. Wainwright U.S. Court of Appeals, Eleventh Circuit". Find a Case. Retrieved November 3, 2011.
- ISBN 9780787663742.
- ^ "Death Qualifications". Capital Punishment In Context. Retrieved November 3, 2011.
- ^ Lindorff, David. "The Death Penalty's Other Victims". Death Penalty Info. Retrieved November 3, 2011.
- S2CID 142065129.
- ^ Conrad, Clay. ""Death-Qualification" Leads to Biased Juries - capital punishment views impact jury selection - Statistical Data Included". USA Today. Retrieved November 3, 2011.
- ^ "Former choirboy Witt is executed in Florida". Park City Daily News. March 6, 1985. Retrieved July 17, 2012.
Further reading
- Dillehay, Ronald C.; Sandys, Marla R. (1996). "Life under Wainwright v. Witt: Juror dispositions and death qualification". Law and Human Behavior. 20 (2): 147–165. S2CID 145150019.
- Stowers, Phillip M. (1985). "Wainwright v. Witt: A New Standard for Death-Qualifying a Capital Jury". West Virginia Law Review. 88 (1): 133–152.