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

In the case of Uttecht v. Brown, 551 U.S. 1 (2007), the underlying events involve Cal Coburn Brown, who committed a series of violent crimes, including the robbery, rape, torture, and murder of one woman in Washington, followed by similar offenses against another woman in California. After confessing to these crimes, Brown pleaded guilty to the California charges and received a life sentence. However, Washington pursued the death penalty, leading to Brown's trial, where he was convicted and sentenced to death. The Washington Supreme Court affirmed his conviction and sentence. The procedural history of the case began when Brown filed a petition for a writ of habeas corpus in the United States District Court for the Western District of Washington, which was denied. Brown then appealed to the United States Court of Appeals for the Ninth Circuit, which reversed the District Court's decision. The Ninth Circuit found that the state trial court had improperly excused a potential juror (Juror Z) for cause, violating Brown's Sixth and Fourteenth Amendment rights. This ruling mandated a new sentencing trial for Brown, more than a decade after his original conviction. The relevant background context includes the legal precedent set by Witherspoon v. Illinois, which addresses the exclusion of jurors based on their views on the death penalty. The Ninth Circuit's decision hinged on the interpretation of this precedent, arguing that the systematic removal of jurors who might oppose the death penalty could compromise the impartiality of the jury. The Supreme Court granted certiorari to review the Ninth Circuit's judgment, ultimately reversing it.

Whether the state trial court violated the Sixth and Fourteenth Amendments by excusing a potential juror for cause based on concerns about impartiality in a capital sentencing trial.

s,” the court held: “The trial court properly exercised its discretion in excusing for cause prospective jurors [X, Y, and Z] during voir dire . Their views would have prevented or substantially impaired their ability to follow the court’s instructions and abide by their oaths as jurors.” Brown, 132 Wash. 2d, at 630, 940 P. 2d, at 598, 599. It is unclear why the Court of Appeals overlooked or disregarded this finding, and it was mistaken in faulting the completeness of the Supreme Court of Washington’s opinion. Even absent this explicit finding, the Supreme Court of Washington’s opinion was not contrary to our cases. The court identified the Witherspoon-Witt rule, recognized that our precedents required deference to the trial court, and applied an abuse-of-discretion standard. 132 Wash. 2d, at 601, 940 P. 2d, at 584. Having set forth that framework, it explained: “[Brown] did not object at trial to the State’s challenge of [Juror Z] for cause. At any rate, [Juror Z] was properly excused. On voir dire he indicated he would impose the death penalty where the defendant ‘would reviolate if released,’ which is not a correct statement of the law. He also misunderstood the State’s burden of proof . . . although he was corrected later. The trial court did not abuse its discretion in excusing [Juror Z] for cause.” Id., at 604, 940 P. 2d, at 585. The only fair reading of the quoted language is that the state court applied the Witt standard in assessing the excusal of Juror Z. Regardless, there is no requirement in a case involving the Witherspoon-Witt rule that a state appellate court make particular reference to the excusal of each juror. See Early v. Packer ,