## Facts

- Dawud Majid Mu’Min, a Virginia inmate serving a sentence for a prior murder, escaped from a highway work detail.
- Mu’Min went to a nearby shopping center, killed and robbed a store owner using a sharpened instrument, then returned to the work crew and discarded evidence.
- The case received extensive local pretrial publicity, including reports about Mu’Min’s prior murder conviction, prison record, parole denials, alleged infractions, and statements suggesting a confession.
- Before trial, Mu’Min moved for a change of venue based on the publicity; the trial court denied the motion.
- During voir dire, the court refused (1) individual voir dire and (2) defense-requested questions asking what specific information prospective jurors had seen or read.
- The court instead asked general questions about exposure and impartiality; jurors who admitted bias or uncertainty were excused.
- Eight of twelve seated jurors acknowledged some exposure to information about the case but stated they had formed no opinion and could be impartial.
- Mu’Min was convicted of capital murder and sentenced to death; the state supreme court affirmed.

## Issues

1. Whether the Sixth Amendment and Fourteenth Amendment require, upon a defendant’s request, voir dire questioning about the specific content of pretrial news reports to which prospective jurors were exposed in a highly publicized case.

## Decision

- Affirmed (5–4).
- The Constitution did not require the trial court to ask content-specific questions about pretrial publicity.
- The trial judge retained broad discretion over the scope and form of voir dire, and the questioning used adequately addressed potential bias.

## Legal Principles

- The constitutional requirement is an impartial jury, not a mandatory set of particular voir dire questions.
- Voir dire must sufficiently address the subject of potential prejudice from pretrial publicity, but content-specific questioning is not categorically required.
- Trial courts have substantial discretion in conducting voir dire, and appellate review gives weight to trial-level judgments about juror impartiality based on answers and demeanor.
- A defendant’s constitutional rights are satisfied when the voir dire provides a reasonable basis to conclude seated jurors can decide the case on the evidence presented at trial.

## Conclusion

The Court held that, even amid significant pretrial publicity, the Sixth Amendment and Due Process Clause do not obligate a state trial court to question prospective jurors about the specific contents of news accounts, so long as the voir dire reasonably tests for bias and supports a finding of juror impartiality.


Mu’Min v. Virginia, 500 U.S. 415 (1991)