It's a matter of life in prison for a woman who drove the getaway car in a deadly Long Beach liquor store robbery that resulted in the murder of a clerk. But for the U.S. Supreme Court, it's a debate over a much narrower legal question: whether a defendant's rights were violated when a juror was removed during the case.
It was nearly two decades ago that Tara Williams drove two men to a Long Beach liquor store. During the robbery, clerk Hung Mun Kim was murdered.
During jury deliberations at Williams’ trial, the judge received a note saying that one of the jurors had “expressed an intention to disregard the law” and had “expressed concern relative to the severity of the charge” of first degree murder. The judge questioned the juror and concluded he was “applying a higher burden of proof than the law requires” and threw him off the jury for bias. The previously deadlocked jury convicted Williams the next day.
Williams appealed, saying the dismissal of the “lone holdout” juror violated her Sixth Amendment rights. The California Court of Appeal rejected her claim. So did the California Supreme Court. But the federal Ninth Circuit Court of Appeals agreed with Williams and said the state appellate court had failed to address Williams' Sixth Amendment claim.
For Judge Stephen Reinhardt, who wrote the Ninth Circuit opinion, the case was a modern-day version of the 1957 film "12 Angry Men." In fact, he began his opinion quoting the film and comparing it to the jury deliberations in the Williams case.
Reinhardt says "12 Angry Men" made for great drama "because it violated the sanctity of the jury's secret deliberations by allowing the audience into the jury room. It was, of course, a work of fiction. We are presented here with a similar intrusion into heated deliberations involving a holdout juror, except that this one took place in open court, and it resulted in a woman being convicted and sentenced to life imprisonment after the holdout was dismissed."
On Wednesday, the U.S. Supreme Court weighs in.
Did the lower court err?
But attorney Kevin Marshall a partner with Jones Day, who filed a friend-of-the-court brief on behalf of the National Association of Criminal Defense Lawyers, says the High Court is two steps away from the actual crime.
"They're not going to talk about whether she was actually involved in the murder," Marshall said. "They're not even going to consider whether the Sixth Amendment was violated." Instead, he says, the justices will decide whether the lower court erred in not directly addressing Williams' claim that her constitutional rights were violated.
It may seem like an arcane legal question, but Marshall says the decision will affect the ability of state prosecutors to defend their convictions when they're challenged in federal court.
Loyola Law School professor Laurie Levenson says the more interesting issue is not being addressed: the circumstances under which a judge can dismiss holdout jurors. Instead, she says, the High Court is focusing on just how much power state and federal courts should have.
So why did the U.S. Supreme Court take up this particular case? Professor Levenson says it's not a surprise: "It's coming out of the Ninth Circuit and the opinion was written by Judge Reinhardt, who seems to be a magnet for the Supreme Court." This particular group of justices has often reversed the Ninth Circuit and Judge Reinhardt in particular.