Spencer v. Georgia

Background

James Lee Spencer, a Black man, was convicted and sentenced to death by a jury of six white and six Black jurors after the prosecutor used nine peremptory strikes to exclude Black venirepersons. Spencer said racial bias affected both jury selection and deliberations and submitted a juror’s affidavit claiming racial slurs and that race influenced some jurors’ votes.

Reasoning

The Supreme Court declined to take the case and deny further review of the state-court decision. The Georgia Supreme Court had rejected Spencer’s claim in part by relying on a state law that limits when juror affidavits can be used to challenge verdicts. The Justices noted that federal courts considering a federal habeas corpus review (a federal process to reexamine state convictions) will have to decide whether that Georgia rule properly blocks federal review.

Real world impact

Because the Supreme Court refused to hear the case, Spencer’s death sentence remains in place for now and the dispute will continue in lower courts. Federal habeas courts must sort out whether state evidentiary rules prevent full federal consideration of his racial-bias claims. This means questions about jury selection, juror statements, and whether race affected the verdict will be addressed further outside the Supreme Court.

Dissents or concurrances

Justice Kennedy wrote a short concurrence saying he trusts federal habeas review will be available to hear the claim. Justice Marshall dissented, stating he would grant review and vacate the death sentence because he views the death penalty as always unconstitutional.