In Re Maurice Boyette on Habeas Corpus

Summary

The California Supreme Court discharged its order to show cause and denied habeas relief on claims that a juror concealed criminal-history and substance-use information, introduced an uncharged murder into deliberations, and encouraged jurors to watch a prison film during penalty deliberations. The court accepted the referee's factual findings because they were supported by substantial evidence and concluded that the concealments did not demonstrate actual bias and that the film-related misconduct did not create a substantial likelihood of juror bias. Justice Corrigan, joined by Justice Liu, concurred in part and dissented in part, concluding that the film misconduct required reversal of the death verdict and a new penalty phase.