Uttecht v. Brown
Encyclopedia
Uttecht v. Brown, 551 U.S. 1
(2007), was a case dealing with jury selection
in capital
cases in which the Supreme Court of the United States
held that appeals courts must defer to a trial judge’s decision on whether a potential juror would be able to overcome demur about capital punishment
and be open to voting to impose a death sentence.
a woman at knifepoint, holding her in a motel for 34 hours, raping, torturing and eventually murdering her, leaving her body in her car's trunk. He was 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, in which he argued in part that the state trial judge had improperly dismissed a juror without finding that the juror's views on capital punishment would impair his ability to follow the law. The district denied his petition and Brown appealed.
The 9th Circuit Court of Appeals reversed the lower court's ruling and upheld Brown's objections as valid finding that the judge's dismissal of the juror infringed upon clear Supreme Court precedent, and that said dismissal prejudiced the jury against the defendant, nullifying his death sentence.
, 469 U.S. 412 (1985), and Darden v. Wainwright, 447 U.S. 168 (1986), established that a state trial judge may, without presenting any explicit findings or conclusions, remove a juror for cause when the judge determines the juror's views on the death penalty would substantially limit his or her ability to follow the law and perform the duties of a juror. Justice Kennedy, writing for the majority, said that appeals courts must defer to a trial judge’s decision on whether a potential juror would be able to overcome qualms regarding the death penalty and be open to voting to impose execution as a sentence.
in Washington state. His execution, once scheduled for March 13, 2009, was stayed
until September 2010, when the Thurston County Superior Court completed a review of the constitutionality of Washington's lethal injection
procedures. The validity of Washington's lethal injection procedures and the competency of the staff administering these duties were upheld on September 7, 2010 and Brown's stay was lifted. Brown was executed on September 10, 2010, the first person executed in the state of Washington since 2001.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2007), was a case dealing with jury selection
Jury selection
Jury selection are many methods used to choose the people who will serve on a trial jury. The jury pool is first selected from among the community using a reasonably random method. The prospective jurors are then questioned in court by the judge and/or attorneys...
in capital
Capital punishment
Capital punishment, the death penalty, or execution is the sentence of death upon a person by the state as a punishment for an offence. Crimes that can result in a death penalty are known as capital crimes or capital offences. The term capital originates from the Latin capitalis, literally...
cases in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that appeals courts must defer to a trial judge’s decision on whether a potential juror would be able to overcome demur about capital punishment
Capital punishment
Capital punishment, the death penalty, or execution is the sentence of death upon a person by the state as a punishment for an offence. Crimes that can result in a death penalty are known as capital crimes or capital offences. The term capital originates from the Latin capitalis, literally...
and be open to voting to impose a death sentence.
Background and court history
Brown was convicted of carjackingCarjacking
Carjacking is a form of hijacking, where the crime is of stealing a motor vehicle and so also armed assault when the vehicle is occupied. Historically, such as in the rash of semi-trailer truck hijackings during the 1960s, the general term hijacking was used for that type of vehicle abduction,...
a woman at knifepoint, holding her in a motel for 34 hours, raping, torturing and eventually murdering her, leaving her body in her car's trunk. He was 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, in which he argued in part that the state trial judge had improperly dismissed a juror without finding that the juror's views on capital punishment would impair his ability to follow the law. The district denied his petition and Brown appealed.
The 9th Circuit Court of Appeals reversed the lower court's ruling and upheld Brown's objections as valid finding that the judge's dismissal of the juror infringed upon clear Supreme Court precedent, and that said dismissal prejudiced the jury against the defendant, nullifying his death sentence.
Question
The question before the Court was whether or not the 9th Circuit Court of Appeals had made an error by not deferring to the trial judge's observations concerning a prospective juror's views on capital punishment 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 federal law.Opinion of the Supreme Court
In a 5-4 conservative-liberal split the majority found that the 9th Circuit had indeed erred when they overruled the Washington State Court's decision and invalidated Brown's death sentence. The precedents of Wainwright v. WittWainwright v. Witt
-Overview:Wainwright vs. Witt was a Supreme Court case argued on October 4, 1984, and denied a rehearing on March 5, 1985. The defendant, Johnny Paul Witt, appealed to the Supreme Court that his 6th and 14th Amendments were violated when he was sentenced to death for first degree murder by the...
, 469 U.S. 412 (1985), and Darden v. Wainwright, 447 U.S. 168 (1986), established that a state trial judge may, without presenting any explicit findings or conclusions, remove a juror for cause when the judge determines the juror's views on the death penalty would substantially limit his or her ability to follow the law and perform the duties of a juror. Justice Kennedy, writing for the majority, said that appeals courts must defer to a trial judge’s decision on whether a potential juror would be able to overcome qualms regarding the death penalty and be open to voting to impose execution as a sentence.
Dissent
The dissenting opinion, joined by Justices Ginsburg, Souter and Breyer, and written by Justice Stevens expressed concern that the decision set the disqualification bar for prospective jurors too low and in effect could cause juries to be more likely to vote for a death sentence.Subsequent events
, Brown remained on death rowDeath row
Death row signifies the place, often a section of a prison, that houses individuals awaiting execution. The term is also used figuratively to describe the state of awaiting execution , even in places where no special facility or separate unit for condemned inmates exists.After individuals are found...
in Washington state. His execution, once scheduled for March 13, 2009, was stayed
Stay of execution
A stay of execution is a court order to temporarily suspend the execution of a court judgment or other court order. The word "execution" does not necessarily mean the death penalty; it refers to the imposition of whatever judgment is being stayed....
until September 2010, when the Thurston County Superior Court completed a review of the constitutionality of Washington's lethal injection
Lethal injection
Lethal injection is the practice of injecting a person with a fatal dose of drugs for the express purpose of causing the immediate death of the subject. The main application for this procedure is capital punishment, but the term may also be applied in a broad sense to euthanasia and suicide...
procedures. The validity of Washington's lethal injection procedures and the competency of the staff administering these duties were upheld on September 7, 2010 and Brown's stay was lifted. Brown was executed on September 10, 2010, the first person executed in the state of Washington since 2001.