Aldridge v. United States

Background

A Black man was tried for first-degree murder after killing a white police officer in the District of Columbia. At jury selection, defense counsel asked the judge to put on the record a question asking each prospective juror whether racial prejudice would prevent them from fairly deciding the case. The judge refused to ask about racial prejudice, counsel noted an exception, and the jury—whose members were white, as admitted in the record—convicted and sentenced the defendant to death.

Reasoning

The Court considered only whether the trial court erred in refusing to ask jurors about racial prejudice. It said questions testing whether a juror’s race-based bias would preclude an impartial verdict are proper and have been recognized in other courts. Because the trial judge did not ask any question covering that subject, and the issue went to the defendant’s right to a fair trial in a case where life was at stake, the Court concluded the refusal was error and reversed the conviction.

Real world impact

Trial judges must allow reasonable questions probing whether prospective jurors hold race-based biases that would prevent a fair verdict, especially in cases with a race difference between defendant and victim. The ruling requires a new look at jury selection in the case and strengthens protections for defendants seeking to uncover disqualifying prejudice.

Dissents or concurrances

A dissent argued the record did not show actual juror bias and that appellate review should not overturn local courts on such speculative grounds; that Justice would have affirmed the conviction.