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The proper standard for determining when a prospective juror may be excluded for cause because of his or her views on capital punishment is whether the juror's views would prevent or substantially impair the performance of his duties as a juror in accordance with his instructions and his oath.
Respondent Johnny Paul Witt was tried by a jury in a Florida state court and convicted of first-degree murder. In accordance with the jury's recommendation, he was sentenced to death. On appeal, respondent claimed that several prospective jurors had been improperly excluded for cause because of their opposition to capital punishment, in violation of the decision in Witherspoon v. Illinois, 391 U.S. 510, but the Florida Supreme Court affirmed the conviction and sentence. After unsuccessfully seeking post-conviction review in the state courts, respondent filed a petition for a writ of habeas corpus in Federal District Court under 28 U.S.C. § 2254; the Federal District Court denied the petition. The Court of Appeals reversed and granted the writ, holding that, on the basis of the voir dire questioning by the prosecutor, one of the prospective jurors was improperly excused for cause under Witherspoon. The State sought review.
Was the prospective juror improperly excused for cause, thereby warranting the grant of respondent’s petition for writ of habeas corpus?
The Court reversed the grant of the petition for a writ of habeas corpus and held that a juror could not be challenged for cause based on his views about capital punishment unless his views would have prevented or substantially impaired the performance of his duties as a juror in accordance with his instructions and his oath. The Court determined that the district court's factual determination that the juror was biased, determined through voir dire, was not erroneous. The transcript of voir dire showed that the prospective juror was questioned in the presence of both counsel and the trial judge, that at the end of the colloquy between the prosecutor and the juror the prosecutor challenged for cause, and that the challenge was sustained. Nothing more was required. The judge was not required to write a specific finding or announce for the record his conclusion that, or his reasons why, the prospective juror was biased. The judge's finding was therefore "presumed correct" absent anything in the record showing one of the reasons enumerated in the statute for avoiding the presumption.