Snyder v. Louisiana

552 U.S. 472 (2008)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

D and his wife had separated. They discussed the possibility of reconciliation, and Mary agreed to meet with D the next day. That night, she went on a date with Howard Wilson. During the evening, D repeatedly attempted to page her, but she did not respond. At approximately 1:30 a.m. on August 16, Wilson drove up to the home of the wife's mother to drop her off. D was waiting at the scene armed with a knife. He opened the driver's side door of Wilson's car and repeatedly stabbed the occupants, killing Wilson and wounding the wife. D was charged with first-degree murder, and the state sought the death penalty based on the aggravating circumstance that D had knowingly created a risk of death or great bodily harm to more than one person. Voir dire started with the court eliminating prospective jurors that had work, family, or other commitments that would interfere with jury service. The court randomly selected panels of 13 potential jurors for further questioning. The defense and prosecution addressed each panel and questioned the jurors both as a group and individually. At the conclusion of this questioning, the court ruled on challenges for cause. Then, the prosecution and the defense were given the opportunity to use peremptory challenges (each side had 12) to remove remaining jurors. The court continued this process of calling 13-person panels until the jury was filled. In accordance with Louisiana law, the parties were permitted to exercise 'backstrikes.' That is, they were allowed to use their peremptories up until the time when the final jury was sworn and thus were permitted to strike jurors whom they had initially accepted when the jurors' panels were called. Eighty-five prospective jurors were questioned as members of a panel. Thirty-six of these survived challenges for cause; 5 of the 36 were black (as is D); and all 5 of the prospective black jurors were eliminated by the prosecution through the use of peremptory strikes. The jury found D guilty of first-degree murder and determined that he should receive the death penalty. On direct appeal, the court rejected D's Batson claim but remanded the case for a nunc pro tunc determination of D's competency to stand trial. The trial court found that D had been competent to stand trial, and the Louisiana Supreme Court affirmed that determination. Eventually, the Supreme Court granted certiorari.