Smith, Correctional Superintendent v. Phillips (SCOTUS 1982)

Summary

The Court reversed the grant of federal habeas relief, holding that due process does not require a new trial whenever a juror is placed in a potentially compromising situation. A post-trial hearing providing an opportunity to prove actual bias was constitutionally sufficient, and the state trial judge's findings were presumptively correct in habeas proceedings. The prosecutors' failure to disclose the juror's employment application required an inquiry into possible bias but, without a showing that the juror was actually biased or that the trial was unfair, did not independently require a new trial.

Holding

Remedy for alleged juror partiality. Due process did not require an automatic new trial based solely on the juror's application for employment with the prosecutor's office. A hearing in which the defendant had an opportunity to prove actual bias was constitutionally sufficient, and the state court's finding that the juror was not biased defeated the claim in this case.

Deference to state-court factfinding in federal habeas proceedings. The federal courts were required to treat the state trial judge's factual findings as presumptively correct because neither lower court identified a basis for overcoming that presumption.

Effect of prosecutorial nondisclosure. The prosecutors' failure to disclose the juror's employment application, although improper and sufficient to require a post-trial inquiry, did not itself violate due process or require a new trial because the record showed no actual juror bias and no unfair trial.

Smith, Correctional Superintendent v. Phillips

Summary

Holding

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