Facts
- Willie Lloyd Turner, a Black man, robbed a Virginia jewelry store and fatally shot the store’s white proprietor.
- Turner was indicted for capital murder based on killing during the course of a robbery.
- During voir dire, Turner requested that prospective jurors be informed of the victim’s race and questioned specifically about racial prejudice.
- The trial judge denied the request and asked only general questions about juror impartiality.
- A jury convicted Turner and, after a separate capital sentencing hearing, recommended the death penalty; the judge imposed a death sentence.
- The Supreme Court of Virginia affirmed the conviction and sentence; federal habeas relief was denied by the district court and affirmed by the Fourth Circuit.
Issues
- In a capital case involving an interracial crime, whether the Constitution entitles the defendant, upon request, to have prospective jurors informed of the victim’s race and questioned specifically about racial bias.
- If such questioning is required, whether the proper remedy is to vacate only the death sentence or also the guilt conviction.
Decision
- The Supreme Court reversed the Fourth Circuit in part and remanded.
- The Court held that a capital defendant accused of an interracial crime is entitled, upon request, to have prospective jurors informed of the victim’s race and questioned on racial prejudice.
- The Court concluded that the refusal to permit race-focused voir dire created an unacceptable risk that racial bias affected the capital sentencing determination.
- The Court vacated Turner’s death sentence and required a new capital sentencing proceeding, but left the guilt conviction undisturbed.
- The trial court retains discretion over the form and number of questions; the constitutional entitlement depends on a specific request by the defendant.
Legal Principles
- In a capital case involving interracial violence, specific voir dire on racial bias is constitutionally required when requested by the defendant.
- The constitutional concern is heightened at capital sentencing because the jury’s broad discretion in weighing aggravating and mitigating circumstances increases the opportunity for impermissible considerations to affect the decision.
- The constitutional requirement is limited and procedural: the trial judge controls the manner of inquiry, and failure to request such questioning at trial forfeits later complaint about its absence.
- When the constitutionally required inquiry is denied, the appropriate remedy is a new sentencing proceeding where the unfairness risk concerns sentencing rather than guilt.
Conclusion
Because a capital sentencing jury’s discretion and the severity of the death penalty create a serious risk that racial prejudice may affect sentencing in interracial crimes, the Constitution requires, upon request, voir dire questioning directed to racial bias; denial of that request requires vacating the death sentence and conducting a new sentencing hearing, while leaving the conviction intact.