Crawford v. Georgia

1989-04-24

Headline: Refusal to review death-row case leaves Georgia conviction and death sentence intact, blocking federal review of venue and juror-prejudice claims despite dissenting Justices urging review and overturning of the sentence.

Holding: The Court denied Eddie Crawford’s petition for review, declining to hear his challenges and leaving Georgia’s conviction and death sentence in place while dissenters urged review and vacatur.

Real World Impact:

Leaves Crawford’s Georgia conviction and death sentence in place.
Keeps Georgia’s change-of-venue standard unreviewed by the Supreme Court.
Highlights dissenters’ view that juror knowledge showed unfair trial risk.

Topics: death penalty, venue and jury bias, state court rulings, appeals and review

Summary

Background

Eddie Crawford was tried, convicted of murder, and sentenced to death in Georgia. The state Supreme Court reversed an earlier conviction because the jury might have convicted him of a different crime not charged. At his retrial, Crawford asked the trial court to move the case to another area and to keep off the jury anyone who knew about the prior trial; both requests were denied. Of 90 possible jurors, 57 knew of the earlier proceedings, 50 knew Crawford had been convicted, and 32 knew he had been sentenced to death. The final jury included eight who knew of the prior trial, five who knew of the conviction, and three who knew of the earlier death sentence.

Reasoning

Crawford asked the United States Supreme Court to review the Georgia court’s decision. The Supreme Court denied his request for review, leaving the Georgia court’s ruling and the new conviction and death sentence in place. The Georgia court had held that the trial setting was not inherently prejudicial and that the jury selection did not show actual prejudice so great that a fair trial was impossible. The Supreme Court’s order does not decide the facts or law on the merits; it simply refused to take the case.

Real world impact

The denial leaves Georgia’s handling of this case and its change-of-venue standard intact for now. Defendants who argue juror knowledge from prior publicity may face a strict standard in Georgia. The Supreme Court’s refusal means the national rules on when states must change venue remain unsettled by this decision.

Dissents or concurrances

Justices Brennan and Marshall dissented from the denial. Both say the death penalty is always unconstitutional and would have granted review and vacated the sentence. Justice Marshall also said Georgia’s venue standard is too demanding and urged the Court to set clearer due process limits.