White v. Wheeler

Background

A prison warden asked the Supreme Court to review a habeas ruling that had overturned a Kentucky man's death sentence. The convicted prisoner was tried for two murders; DNA linked him to the scene, he was convicted, and the Kentucky Supreme Court affirmed the death sentence. During jury selection, a prospective juror (Juror 638) gave inconsistent and equivocal answers about whether he could realistically consider the death penalty, and the trial judge later excused him for cause. After state appeals and postconviction procedures ended, a federal appeals court granted habeas relief and overturned the sentence.

Reasoning

The Court addressed whether excusing Juror 638 violated the Constitution and whether the federal court properly applied the strict deference owed to state courts under federal habeas law (AEDPA). Relying on earlier cases about death-penalty juror disqualification, the Court said only jurors who are substantially impaired can be excused, but judges are entitled to wide discretion when answers are ambiguous. The Supreme Court concluded the trial judge reasonably found Juror 638 ambiguous and could be excused, and the Sixth Circuit failed to give the double layer of deference required on habeas review. The Court reversed the appeals court and sent the case back for further proceedings consistent with that conclusion.

Real world impact

The decision reinforces trial judges' authority to remove jurors who give unclear answers about capital punishment and restricts federal courts' ability to overturn such state-court rulings on habeas review. The ruling emphasizes that AEDPA's deferential standard applies fully in death-penalty cases.