Facts
- William C. Witherspoon was convicted of murdering a Chicago police officer in Cook County, Illinois.
- Illinois law permitted challenges for cause of any prospective juror who stated conscientious scruples against capital punishment or opposition to it.
- During voir dire, the prosecution successfully challenged 47 veniremembers for cause based on their attitudes toward the death penalty.
- Most excluded veniremembers were not asked whether their views would prevent them from considering a death sentence in the particular case.
- The jury found Witherspoon guilty and fixed the penalty at death.
- Illinois courts denied post-conviction relief and upheld the conviction and death sentence.
- The U.S. Supreme Court reviewed whether the Constitution permits execution pursuant to a death verdict returned by a jury selected in this manner.
Issues
- Whether the Sixth and Fourteenth Amendments allow a State to execute a defendant when the sentencing jury was selected by excluding for cause all prospective jurors who voiced general objections to, or conscientious scruples against, the death penalty.
- Whether such exclusions require reversal of the conviction for guilt, the death sentence, or both.
Decision
- The Court held that a death sentence may not be carried out if the jury that imposed or recommended it was chosen by excluding for cause veniremembers solely because they expressed general objections to the death penalty or conscientious or religious scruples against it.
- The Court ruled that this practice produced a jury that was not impartial on the punishment question, in violation of the Sixth and Fourteenth Amendments.
- The Court left the conviction for murder intact, concluding the record did not establish that such exclusions made the guilt determination unrepresentative or materially increased the risk of conviction.
- The remedy was limited to setting aside the death sentence.
Legal Principles
- A State may exclude for cause prospective jurors whose views on capital punishment would prevent them from making an impartial decision as to guilt.
- A State may exclude for cause prospective jurors who state they would never vote to impose the death penalty or would refuse to consider its imposition in the case before them.
- A State may not exclude for cause jurors who merely oppose capital punishment in principle or have conscientious scruples against it but can still follow the law and consider a death sentence.
- A capital sentencing jury must be impartial on punishment; excluding all jurors with general anti-death-penalty views improperly biases the sentencing decision toward death and violates the Sixth and Fourteenth Amendments.
Conclusion
The Court invalidated Witherspoon’s death sentence because the State removed jurors for cause based on general opposition to capital punishment, creating a sentencing jury biased in favor of death; the murder conviction was affirmed.