Greene v. Georgia

Background

A man convicted in Georgia of murder, armed robbery, and aggravated assault was sentenced to death after a jury trial. During jury selection, the trial judge, over the defendant’s objection, excused five prospective jurors who said they had reservations about the death penalty. The Georgia Supreme Court affirmed the conviction and relied on Wainwright v. Witt as controlling authority to give deference to the trial judge’s findings about juror bias.

Reasoning

The central question was whether the federal Witt standard — developed in the context of federal habeas review — binds a state high court when it reviews a trial judge’s decision to disqualify jurors for their views on capital punishment. The Court explained that Witt arose under federal habeas law and that the federal statute governing habeas review requires a presumption of correctness for state court findings. That federal rule does not automatically set the standard that state appellate courts must use. The Court concluded the Georgia Supreme Court was mistaken to treat Witt as mandatory, reversed that court’s judgment, and remanded the case for further proceedings consistent with this opinion. The opinion also notes that the State may choose to follow Witt if it wishes, but it is not required to do so.

Real world impact

This decision affects how state courts review juror-bias rulings in capital cases. State high courts remain free to set their own standards for reviewing trial judges’ credibility and demeanor findings. The ruling does not decide whether the excluded jurors were actually biased; it only corrects the legal standard the Georgia court applied, so further proceedings will follow.