Darden v. Wainwright
In Darden v. Wainwright, 477 U.S. 168 (1986), the United States Supreme Court reinforced its rule of deference in reviewing trial court decisions to exclude jurors in death penalty cases due to their opposition to the death penalty.
The State had challenged a potential juror, and the defense had not objected to his removal. Without further questioning from the trial court, the juror was excused. Id. at 178. The petitioner argued to the Supreme Court that the transcript of voir dire did not show that the removed juror was substantially impaired because the critical answer he had given was ambiguous. The Court rejected this argument. "Our inquiry does not end with a mechanical recitation of a single question and answer." Id. at 176.
The Court held that even when "the precise wording of the question asked of [the venireman], and the answer he gave, do not by themselves compel the conclusion that he could not under any circumstance recommend the death penalty," the need to defer to the trial court remains because so much may turn on a potential juror's demeanor. Id. at 178. The absence of an objection, and the trial court's decision not to engage in further questioning as it had prior to excusing other jurors, supported the conclusion that the juror was impaired. Ibid.