Boulden v. Holman

Background

A man convicted of first-degree murder in Alabama was sentenced to death after a jury verdict. He challenged the admission of a confession and sought federal habeas review after state and federal courts upheld his conviction. The Supreme Court agreed to review the case and examined both the confession and later-raised questions about how the death-penalty jury was chosen.

Reasoning

The Court studied the full record and concluded the confession introduced at trial was not shown to be involuntary under the constitutional standards that applied before later Miranda rules. However, the Court noted that the prosecution used an Alabama law to excuse at least 15 prospective jurors who expressed opposition to capital punishment. Because of Witherspoon v. Illinois, excluding jurors simply for general objections to the death penalty can make a death sentence unconstitutional. The Court therefore vacated the appeals-court judgment and remanded the case for a focused hearing on whether jurors were improperly excluded.

Real world impact

The decision requires a lower court to review jury selection and could lead to relief from the death sentence if jurors were disqualified improperly. It leaves the voluntariness finding intact for now but does not finally decide the jury issue. Local courts will be asked to consider state procedures and whether the defendant exhausted state remedies before any final action on the sentence.

Dissents or concurrances

Three Justices (joined by two others) agreed with the remand but urged the lower court also to examine earlier events: the Justice noted a separate, earlier episode at the crime scene where officers may have threatened the defendant and where initial admissions were made, which could affect the voluntariness question.