## Facts

- Cal Coburn Brown committed aggravated murder in Washington after robbing, raping, torturing, and killing Holly Washa; he later committed similar violent crimes in California.
- Washington prosecuted Brown for aggravated first-degree murder and sought the death penalty.
- During capital voir dire, the court conducted an extended “death qualification” process focused on prospective jurors’ views on capital punishment.
- One prospective juror (“Juror Z”) gave inconsistent and ambiguous answers about whether he could vote for the death penalty and follow the court’s instructions.
- The trial judge excused Juror Z for cause, concluding Juror Z’s ability to apply the law and consider a death sentence was substantially impaired.
- Brown was convicted and sentenced to death; the Washington Supreme Court affirmed.
- In federal habeas proceedings, the Ninth Circuit granted relief, concluding the excusal of Juror Z violated the Sixth and Fourteenth Amendments because the record did not show substantial impairment.

## Issues

1. Whether, under *Witherspoon* and *Wainwright v. Witt*, the trial court permissibly excused Juror Z for cause based on substantial impairment regarding the death penalty.
2. Whether AEDPA required the federal habeas court to defer to the state court’s determination, including the trial judge’s assessment of juror demeanor and credibility.
3. Whether the Ninth Circuit improperly substituted its own view of the voir dire record for the trial court’s judgment.

## Decision

- The Supreme Court reversed the Ninth Circuit and remanded.
- The Court held the trial judge acted within discretion in excusing Juror Z for cause under the *Witt* substantial-impairment standard.
- The Court held that AEDPA required deference to the state court’s adjudication and that the Ninth Circuit failed to apply the required deference.
- The Court emphasized that trial judges may rely on the full context of voir dire and are not required to make detailed, juror-specific findings on the record.

## Legal Principles

- A capital defendant is entitled to an impartial jury drawn from a venire not skewed toward death by improper cause challenges.
- The State has a legitimate interest in seating jurors who can apply capital punishment within the governing legal framework.
- A prospective juror may be removed for cause when the juror’s views on the death penalty would “substantially impair” performance of the juror’s duties under the court’s instructions and oath.
- Demeanor-based determinations about substantial impairment are primarily for the trial court and receive substantial deference on review.
- Under AEDPA, federal habeas relief is unavailable unless the state-court decision is contrary to, or an unreasonable application of, clearly established Supreme Court precedent, or rests on an unreasonable determination of facts; this constrains federal courts from reweighing voir dire transcripts de novo.

## Conclusion

The Court held that, on federal habeas review, a state trial judge’s decision to excuse a prospective juror in a capital case for substantial impairment is entitled to strong deference, and AEDPA bars relief where the state court’s application of *Witt* is at least reasonable.


Uttecht v. Brown, 551 U.S. 1 (2007)