Turner v. Murray

1986-04-30

Headline: Capital interracial murder cases: Court requires jurors be told the victim’s race and asked about racial bias, vacating the death sentence while leaving the conviction in place for now.

Holding: The Court held that a capital defendant accused of an interracial violent crime must be allowed to have prospective jurors informed of the victim’s race and questioned about racial bias, vacating the death sentence while preserving the conviction.

Real World Impact:

Requires judges to ask jurors about racial bias in capital interracial cases.
Makes it easier to vacate death sentences when race-related jury questioning was refused.
Leaves guilt convictions intact unless separate error is shown at the guilt phase.

Topics: capital punishment, jury selection, racial bias in trials, death penalty

Summary

Background

A Black man was tried for the murder of a white storekeeper during an armed robbery. The trial judge declined defense counsel’s request to ask prospective jurors whether the defendant’s or victim’s race would affect their fairness. The jury (eight white and four Black jurors) convicted him and recommended death; the trial court imposed the death sentence and the conviction was affirmed on state review before federal review reached this Court.

Reasoning

The Court considered whether a capital defendant accused of an interracial violent crime must be allowed to have prospective jurors informed of the victim’s race and questioned on racial bias. The majority held that three factors together made such inquiry constitutionally required: (1) interracial violence, (2) the broad discretion a jury has in deciding a death sentence, and (3) the special finality and seriousness of capital punishment. The Court emphasized that the risk of racial prejudice could be reduced easily by asking the question, so the judge’s refusal was reversible error at sentencing.

Real world impact

On these facts the Court vacated the death sentence and ordered a new sentencing proceeding rather than a new trial on guilt. The ruling means capital defendants accused of interracial violent crimes can request that jurors be told the victim’s race and questioned about racial bias; trial judges retain discretion over the form of questions and whether to question collectively or individually.

Dissents or concurrances

Justice Brennan and Justice Marshall would have reversed both the sentence and the conviction, arguing jury questioning is required at both guilt and sentencing phases; Justice Powell dissented, opposing a per se rule for capital cases.