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A capital defendant accused of an interracial crime is entitled to have prospective jurors informed of the race of the victim and questioned on the issue of racial bias.
Prior to the commencement of voir dire in a Virginia state court trial of Willie Lloyd Turner, a black defendant, on charges including capital murder, the judge refused a defense request to question the prospective jurors specifically as to whether the difference in races of the defendant and the victim, who was white, would prejudice the jurors. Instead, the trial judge only questioned the prospective jurors generally as to whether they knew of any reason why they could not render a fair and impartial verdict, at a time when the jurors had no way of knowing the victim was white. Eventually, the jury which was empaneled convicted the defendant on all charges including capital murder, and, in a separate capital sentencing hearing, recommended the defendant be sentenced to death, a recommendation the trial judge accepted. After unsuccessful attempts in earlier proceedings to overturn the verdict, the defendant sought habeas corpus relief in the United States District Court for the Eastern District of Virginia, arguing that the trial judge's refusal to ask prospective jurors about their racial attitudes deprived him of a right to a fair trial. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the District Court's denial of habeas corpus, expressing the view that there were no "special circumstances" in the case to justify such voir dire questioning, due to either the nature of the crime or punishment itself, or the fact that the defendant was black and the victim was white. The United States Supreme Court granted a writ of certiorari.
Did the trial judge commit reversible error at voir dire by refusing defendant’s request to question prospective jurors on racial prejudice?
The United States Supreme Court reversed the judgment of the Court of Appeals and remanded for further proceedings, holding that the trial judge committed reversible error, because capital defendants in cases involving interracial crime were entitled to have prospective jurors informed of the race of the victim and questioned on the issue of racial bias. The Court found that the risk that racial prejudice may have infected defendant's capital sentencing was unacceptable in light of the ease with which that risk could have been minimized. By refusing to question prospective jurors on racial prejudice, the trial judge failed to adequately protect defendant's constitutional right to an impartial jury. The inadequacy of voir dire required that defendant's death sentence be vacated.