## Facts

- Willie Jasper Darden was convicted in Florida state court of murder, robbery, and assault with intent to kill arising from a furniture store robbery in which the owner was killed and a neighbor intervenor was shot.
- Under Florida’s capital sentencing procedure, the jury returned a nonbinding recommendation of death, and the trial judge imposed a death sentence.
- During jury selection, the trial court excused a prospective juror for cause based on opposition to the death penalty.
- During guilt-phase closing argument, the prosecutor made highly inflammatory remarks, including dehumanizing characterizations of Darden and comments implying a personal desire that Darden were dead.
- On direct review, the Florida Supreme Court affirmed the conviction and sentence, rejecting challenges to the closing argument and the juror’s exclusion.
- In federal habeas proceedings, Darden renewed those claims and also alleged ineffective assistance of counsel at the penalty phase; the district court denied relief and the Eleventh Circuit affirmed.

## Issues

1. Whether excusing a prospective juror for cause due to death-penalty views violated the Constitution under the “prevent or substantially impair” standard.
2. Whether the prosecutor’s inflammatory guilt-phase closing argument rendered the trial fundamentally unfair in violation of due process and undermined the reliability required in a capital case.
3. Whether trial counsel provided ineffective assistance at the sentencing phase under the deficient-performance and prejudice requirements.

## Decision

- The Supreme Court affirmed the denial of federal habeas relief.
- The Court held the voir dire record, considered in context, supported excusing the juror because his views would prevent or substantially impair performance of juror duties.
- The Court held the prosecutor’s remarks were improper but did not so infect the trial with unfairness as to deny due process, given the trial context, the opportunity for defense rebuttal, jury instructions that argument is not evidence, and the substantial evidence of guilt.
- The Court held Darden failed to prove ineffective assistance at sentencing because counsel’s conduct was not constitutionally deficient and Darden did not show a reasonable probability of a different sentencing outcome.

## Legal Principles

- A capital juror may be excused for cause when the juror’s views on capital punishment would prevent or substantially impair performance of duties in accordance with instructions and oath; the determination is evaluated from the full voir dire context.
- Improper prosecutorial summation violates due process only if it so infects the trial with unfairness that the resulting conviction is a denial of due process; courts assess the remarks in context, including instructions, rebuttal opportunities, and the strength of the evidence.
- Ineffective assistance claims are governed by the two-part test requiring deficient performance and prejudice; at sentencing, the defendant must show a reasonable probability that, but for counsel’s errors, the result would have been different.

## Conclusion

The Supreme Court left Darden’s conviction and death sentence intact, concluding that the challenged juror excusal satisfied the governing standard, the prosecutor’s inflammatory argument did not rise to a constitutional due process violation in context, and Darden did not establish ineffective assistance at capital sentencing under the required showing of deficiency and prejudice.


Darden v. Wainwright, 477 U.S. 168 (1986)