Texas v. Mead

Background

A man convicted of killing a police officer in Texas was sentenced to death. During jury selection, a potential juror said he would never vote for the death penalty. The trial judge excused that juror for cause. The Texas Court of Criminal Appeals later reversed the trial court, ordered a new trial, and the State of Texas asked the Supreme Court to review that ruling.

Reasoning

The main question was whether appellate courts should give special deference to a trial judge’s decision about a juror’s attitude toward the death penalty, or instead reexamine the transcript and decide the matter anew. Justice Stevens explained that the specific deference question was not presented in Texas’s petition, so the Court denied review. Justice Rehnquist (joined by the Chief Justice and Justice O’Connor) dissented from the denial and would have granted review to resolve the split among many state and federal courts.

Real world impact

Because the Supreme Court refused to take the case, the Texas court’s reversal and order for a new trial remain in effect in this case. The broader question about how much weight appellate courts must give to trial judges’ firsthand observations of jurors remains unsettled. That uncertainty means different states and federal courts will continue using varied review practices until the Court decides the issue in a future case.

Dissents or concurrances

The dissent stressed widespread confusion among jurisdictions and argued the Court should clarify that trial judges normally deserve deference when judging juror credibility and bias.