Monday, December 23, 2013

Smith v. Phillips case brief

Smith v. Phillips case brief summary
455 U.S. 209 (1982)

Petitioner, a correctional superintendent, sought review of a decision of the United States Court of Appeals for the Second Circuit affirming a writ of habeas corpus granted to respondent after respondent was convicted on two counts of murder and one count of attempted murder.

Respondent was convicted of murder and attempted murder and filed a motion to vacate his conviction based on the fact that a juror in respondent's case submitted during the trial an application for employment as a major felony investigator in the district attorney's office. The office received the application, but the juror was not contacted during the trial. Before the end of respondent's trial, the prosecutors were informed of the situation and determined that no more information about the juror was revealed than during voir dire.


  • A decision affirming a grant of habeas corpus to respondent was reversed. 
  • Due process meant a jury capable and willing to decide the case solely on the evidence before it. 
  • A determination that the juror was not biased was made after a hearing by the trial judge. 
  • Nothing in the case suggested that the prosecutors' conduct was undertaken in bad faith. 
  • The juror's conduct did not impair his ability to render an impartial verdict.

The court reversed the judgment.

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