White v. Wheeler

PETITIONER: Randy White, Warden
RESPONDENT: Roger L. Wheeler
LOCATION: Jefferson Circuit Court Criminal Division

DOCKET NO.: 14-1372
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Sixth Circuit

CITATION: 577 US (2015)
GRANTED: Dec 14, 2015
DECIDED: Dec 14, 2015

Facts of the case

In October 1997, Nigel Malone and Nairobi Warfield were found dead in their apartment. Blood at the crime scene matched Roger L. Wheeler’s, and he was arrested for the murders. During voir dire, one of the potential jurors gave equivocal responses in response to questions regarding his beliefs about the death penalty. The prosecution moved to strike the juror for cause and cited these replies. The defense opposed the motion and argued that the responses indicated nothing more than an ability to consider all penalty options. The judge struck the juror, and Wheeler was subsequently convicted of the murders and sentenced to death. The Kentucky Supreme Court affirmed the convictions and the sentence and held that the trial judge appropriately struck all the jurors who could not impose the death penalty.

Wheeler exhausted his state post-conviction proceedings and petitioned for a writ of habeas from the federal district court. The federal district court denied the petition, but the U.S. Court of Appeals for the Sixth Circuit reversed, granted the petition, and held that the exclusion of the juror in question was an unreasonable application of the Supreme Court’s precedent in Witherspoon v. Illinois. In that case, the Supreme Court held that only a juror who is “substantially impaired in his or her ability to impose the death penalty” can be excused for cause. The appellate court held that the trial court erred in interpreting the juror’s responses that he did not know if he could consider the death penalty as meaning that he could not consider the death penalty.

Question

Was the decision to strike a potential juror based on that juror’s equivocal statements about his ability to consider the death penalty a reasonable application of the Supreme Court’s precedence as established in Witherspoon v. Illinois?