Institution of Affiliation
MORGAN v. ILLINOIS,
Supreme Court of the United States,
504 U.S. 719 (1992) FACTS
Derrick Morgan was indicted alongside others by a grand jury in Cook County on two different accounts. On one count, he was accused of murder while on the other he was accused of armed violence which resulted in the death of David Smith. The armed violence charge that had been brought against him was dropped but after a trial by the jury, he was found guilty of first-degree murder which resulted in a death sentence. In Illinois, the trial of a capital offense takes place in two phases where the same jury is responsible for determining the defendant’s guilt and the viability of a death penalty. The defendant’s counsel requested the court to ask the potential jurors whether they would impose a death penalty on the defendant regardless of the fact but the court denied the request. Upon appeal, the Supreme Court affirmed the trial court’s conviction and the death sentence.
Based on impartial jury requirement in the fourteenth amendment and the sixth amendment, does the due process prevent a state from asking whether the juror involved would impose an automatic death penalty vote on a defendant accused of a capital offense?
The supreme court held that the defendant who was facing a dealt penalty had the right to challenge for cause a prospective juror with the intention of voting an automatic death penalty. The held that the sixth amendment had been violated which resulted in a remand instead of a death penalty.
The opinion of the majority was of the argument that according to the Due Process clause contained in the Fourteenth and the Sixth Amendments requirement of an impartial jury, the defendant had a right to an impartial jury. The court decided that an automatic vote for a death penalty by the juror would be a sign of prejudice which was a violation of the defendant’s sixth amendment rights to an impartial jury. The court was of the opinion that the juror is questioned to determine its credibility in the case that should have been free from bias. The supreme court which had affirmed the trial court’s decision to sentence Morgan to a death penalty thus reversed its decision.
The above case involves the violation of the sixth amendment where the trial court had denied the defendant his constitutional right to an impartial jury. The defendant’s counsel had been denied the right to question the jurors on the possibility of voting an automatic death penalty.
Rule of Law
According to the sixth amendment, a defendant has the right to an impartial jury which means the jury should show no signs of bias. The defendant has the right to meet and question witnesses against him to ensure that there is no bias. The trial court denied Morgan this privilege.
The trial court failed to follow the legal guidelines when imposing a death sentence upon Morgan by denying him the right to question the juror. Had the trial court given him the chance to question the council, the ruling would have taken a different dimension that was constitutional.
Initially, the supreme court had upheld the ruling of the trial court. The supreme court reviewed the ruling and after detecting violation of the defendant right to a legal counsel, it reversed the ruling and remanded the defendant.
Justia. (n.d.). Morgan v. Illinois, 504 U.S. 719 (1992). Retrieved from https://supreme.justia.com/cases/federal/us/504/719/