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Morgan v. Illinois - 504 U.S. 719, 112 S. Ct. 2222 (1992)

Rule:

A juror who will automatically vote for the death penalty in every case will fail in good faith to consider the evidence of aggravating and mitigating circumstances as the instructions require him to do. Indeed, because such a juror has already formed an opinion on the merits, the presence or absence of either aggravating or mitigating circumstances is entirely irrelevant to such a juror. Therefore, based on the requirement of impartiality embodied in the Due Process Clause of the Fourteenth Amendment, a capital defendant may challenge for cause any prospective juror who maintains such views. If even one such juror is empaneled and the death sentence is imposed, the state is disentitled to execute the sentence.

Facts:

An Illinois trial court, conducting voir dire in a capital case, questioned each venire--at the request of the prosecution, and over defense objections--whether any member had moral or religious scruples that would prevent the member from imposing the death penalty regardless of the facts. The trial court refused a defense request to ask prospective jurors whether they would automatically vote to impose the death penalty if they found the defendant guilty, as the trial court found that it had asked substantially the same question in a different manner--the court having asked 9 of the 12 jurors eventually impaneled whether they would follow his instructions on the law even if they disagreed, and all of the jurors whether they felt that they could be fair and impartial. When impaneled, the jurors swore an oath to render a verdict according to the law and the evidence. The jury thereafter convicted the defendant of first-degree murder and sentenced him to death. In affirming the conviction and sentence on appeal, the Supreme Court of Illinois held that there was no rule requiring a trial court to "life qualify" a jury to exclude all jurors who believed that the death penalty should be imposed in every murder case. Moreover, the Supreme Court of Illinois held that the defendant's sentence was valid, given that none of the jurors actually selected either expressed any views that would call his or her impartiality into question, or was shown to be biased in favor of the death penalty. The defendant sought review. 

Issue:

By refusing to inquire whether potential jurors would automatically impose the death penalty upon convicting defendant, did the trial court violate defendant’s due process rights? 

Answer:

Yes.

Conclusion:

On appeal, the court found that defendant was entitled, upon his request, to inquiry discerning those jurors who, even prior to the state's case in chief, had predetermined the terminating issue of his trial, that being whether to impose the death penalty. The court explained that any juror who stated that he or she would automatically vote for the death penalty without regard to the mitigating evidence would be announcing an intention not to follow the instructions to consider the mitigating evidence and to decide if it was sufficient to preclude imposition of the death penalty. Accordingly, the court held that defendant was entitled to relief under the Due Process Clause of the Fourteenth Amendment.

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