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The constitutional standard of fairness requires that a defendant have a panel of impartial, indifferent jurors. Qualified jurors need not, however, be totally ignorant of the facts and issues involved. To hold that the mere existence of any preconceived notion as to the guilt or innocence of an accused, without more, is sufficient to rebut the presumption of a prospective juror's impartiality would be to establish an impossible standard. It is sufficient if the juror can lay aside his impression or opinion and render a verdict based on the evidence presented in court. At the same time, the juror's assurances that he is equal to this task cannot be dispositive of the accused's rights, and it remains open to the defendant to demonstrate the actual existence of such an opinion in the mind of the juror as will raise the presumption of partiality.
Murphy, a state prisoner convicted in the Dade County, Florida, Criminal Court of two felonies, filed, after an unsuccessful appeal from the judgment of conviction, a petition for habeas corpus in the United States District Court for the Southern District of Florida, alleging that his confinement was unlawful because the state trial court had denied his motions to dismiss the chosen jurors and for a change of venue, these motions being based on the ground that through pretrial publicity, the jurors were aware of his prior criminal record or certain facts about the crime charged. The District Court denied relief, and the United States Court of Appeals for the Fifth Circuit affirmed.
Was Murphy denied a fair trial because members of the jury had learned from news accounts about a prior felony conviction or certain facts about the crime with which he was charged?
The appellate court's judgment was affirmed. The Court held that it was unable to conclude the pretrial publicity caused actual prejudice against Murphy to a degree that rendered a fair trial impossible. Murphy had failed to show that the setting of the trial was inherently prejudicial or that the jury-selection process of which he complained permitted an inference of actual prejudice. While the constitutional standard of fairness required that a defendant had a panel of impartial indifferent jurors, qualified jurors were not required to be totally ignorant of the facts and issues involved.