White v. Woodall

572 U.S. 415 (2014)

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Nature of the Case

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Facts

Sarah drove to a convenience store to rent a movie. When she failed to return home several hours later, her family called the police. Officers eventually found the vehicle Sarah had been driving a short distance from the convenience store. They followed a 400- to 500-foot trail of blood from the van to a nearby lake, where Hansen’s unclothed, dead body was found floating in the water. Hansen’s “throat had been slashed twice with each cut approximately 3.5 to 4 inches long,” and “her windpipe was totally severed.” P had been in the convenience store on the night of the murder. P gave conflicting statements regarding his whereabouts that evening. P’s “fingerprints were on the van the victim was driving,” “blood was found on P's front door,” “blood on his clothing and sweatshirt was consistent with the blood of the victim,” and “DNA on . . . vaginal swabs” taken from the victim “was consistent with” P’s. P pleaded guilty to capital murder. He also pleaded guilty to capital kidnaping and first-degree rape, the statutory aggravating circumstance for the murder. At the penalty-phase trial, P called character witnesses but declined to testify himself. P asked the trial judge to instruct the jury that “[a] defendant is not compelled to testify and the fact that the defendant did not testify should not prejudice him in any way.” The judge denied the request, and the Kentucky Supreme Court affirmed that denial. The court held that our subsequent cases did not require such an instruction. The Supreme Court denied P’s petition for a writ of certiorari from a direct appeal. In 2006, P filed this petition for habeas corpus in Federal District Court. It held that the trial court’s refusal to issue a no-adverse-inference instruction at the penalty phase violated P’s Fifth Amendment privilege against self-incrimination. The Court of Appeals affirmed and ordered D to either resentence P within 180 days or release him. The Supreme Court granted certiorari.