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It is not enough that the prosecutors' remarks were undesirable or even universally condemned. The relevant question is whether the prosecutors' comments so infected the trial with unfairness as to make the resulting conviction a denial of due process. Moreover, the appropriate standard of review for such a claim on writ of habeas corpus is the narrow one of due process, and not the broad exercise of supervisory power.
After a jury trial in a Florida court, Darden was found guilty of murder, robbery, and assault with intent to kill. Pursuant to Florida's capital sentencing statute, the same jury heard further testimony and argument, and made a nonbinding recommendation that the death penalty be imposed. The trial judge followed that recommendation, and the Florida Supreme Court affirmed the conviction and the sentence, rejecting Darden’s contention that the prosecution's closing argument during the guilt phase of the trial rendered the trial fundamentally unfair and deprived the sentencing determination of the reliability required by the Eighth Amendment. The court also rejected Darden’s contention that the trial court erred in excluding a member of the venire for cause on the basis of his affirmative response to the judge's question during voir dire "Do you have any moral or religious, conscientious moral or religious principles in opposition to the death penalty so strong that you would be unable without violating your own principles to vote to recommend a death penalty regardless of the facts?" In subsequent federal habeas corpus proceedings, Darden raised the same claims, as well as the additional claim that he had been denied effective assistance of counsel at the sentencing phase of his trial. The District Court denied relief, and the Court of Appeals ultimately affirmed the District Court's judgment in all of its aspects.
Did the improper remarks in prosecution's summation deprive Darden of fair trial or violate 8th Amendment?
The Court held that no specific objection was made to the excusal of the juror by defense counsel. Viewing the record of voir dire in its entirety, the decision to exclude the juror was proper. Further, the weight of the evidence against Darden was heavy, and the overwhelming eyewitness and circumstantial evidence to support a finding of guilt reduced the likelihood that the jury's decision was influenced by the improper closing argument. Also, the record indicated that a great deal of time and effort went into the defense of the case, and a significant portion of that time was devoted to preparation for sentencing. Darden failed to satisfy the test that his trial counsels' performance fell below an objective standard of reasonableness. The Court held that Darden was not deprived of the effective assistance of counsel.