Supreme Court of the United States

Wainwright v. Witt

January 21, 1985469 U.S. 412

Summary

The Supreme Court reversed the Eleventh Circuit, holding that a state trial judge’s decision to excuse a juror for cause under the Witherspoon framework is a factual finding subject to the presumption of correctness under 28 U.S.C. §2254(d) and must be evaluated using the Adams test – whether the juror’s views would prevent or substantially impair performance of juror duties. Accordingly, the trial judge’s exclusion of juror Colby was proper and the death sentence was upheld.

Holding

  • What is the proper standard for excluding jurors in capital cases – the Witherspoon footnote 21 formulation or the Adams test?. The Court adopts the Adams test as the proper standard: a juror may be excluded for cause only if his or her views would prevent or substantially impair the performance of juror duties in accordance with instructions and oath.
  • Whether a state trial judge’s determination that a juror should be excluded for cause is a factual finding subject to the presumption of correctness under 28 U.S.C. §2254(d) in federal habeas review.. Such determinations are factual issues and therefore entitled to the presumption of correctness under §2254(d).
  • Whether juror Colby’s statements satisfied the Adams standard, justifying her exclusion and upholding Witt’s death sentence.. Colby’s statements were sufficient to show that her views would prevent or substantially impair her ability to perform juror duties, so her exclusion was proper.

Docket 83-1427

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