Tuesday, November 5, 2013

Darden v. Wainwright case brief

Darden v. Wainwright case brief summary
477 U.S. 168 (1986)

Defendant sought review by certiorari of a judgment of the United States Court of Appeals for the Eleventh Circuit, which affirmed his death sentence after he was found guilty of murder, robbery, and assault with intent to kill.

Defendant challenged his conviction and death sentence as to (1) whether the exclusion for cause of a member of the jury violated certain principles; (2) whether the prosecution's closing argument rendered the trial fundamentally unfair; and (3) whether he was denied effective assistance of counsel at the sentencing phase of his trial.

  • The Court held that no specific objection was made to the excusal of the juror by defense counsel. 
  • Viewing the record of voir dire in its entirety, the decision to exclude the juror was proper. 
  • Further, the weight of the evidence against defendant was heavy, and the overwhelming eyewitness and circumstantial evidence to support a finding of guilt reduced the likelihood that the jury's decision was influenced by the improper closing argument. 
  • Also, the record indicated that a great deal of time and effort went into the defense of the case, and a significant portion of that time was devoted to preparation for sentencing. 
  • Defendant failed to satisfy the test that his trial counsels' performance fell below an objective standard of reasonableness. 
  • The Court held that defendant was not deprived of the effective assistance of counsel.

The Court affirmed the judgment.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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