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Massachusetts SJC holds jurors can bring personal world view into jury service and avoid challenge for cause in Commonwealth v. Quinton Williams

The SJC decided the case of Commonwealth v. Quinton Williams finding that the trial judge did not error by excluding a juror who stated that the criminal justice system was rigged against young black Americans.  The SJC in the majority opinion and concurring opinion of the Chief Justice stated that it would not be proper to exclude the juror for cause based on this opinion, which the Court indicated has empirical support so is closer to a fact than opinion.

The Court found that the trial judge properly excluded the juror because of her equivocation about whether she could be fair and impartial.  The Chief Justice in his concurring opinion indicated that the court gives great deference to a trial judge questioning a juror as the questions are quick and spontaneous.  The Chief Justice indicated that while he would not have excluded the juror and may have asked more questions, that he did not find a reversible error in the decision to exclude the juror.

The defendant argued that if the court strikes a juror for cause improperly, the court should automatically reverse the conviction as it is a structural error in the trial, the equivalent of giving the Commonwealth and extra peremptory challenge.  The Court rejected the argument that this is the same as denying the defendant a peremptory challenge finding that the juror was presumably replaced with another fair juror.  The Court found that a defendant is not entitled to a a jury of any particular composition.

In its decision, the Court emphasized that under the Sixth Amendment a defendant is entitled to an impartial jury.  The SJC stated that each juror must be impartial as the persons involved and unprejudiced and uncommitted as the defendant guilty or past misconduct.  It is the function of the court to determine if a juror has an attitudes, opinions which may cause the case to be decided on extraneous issues.

An important point in Chief Justice Gant’s concurring opinion is that it is improper to exclude a juror based on the lenses that a juror views a case from.  In this case, the juror indicated that she understand racial bias against young black Americans.  The Chief Justice stated it is okay to ask a juror to set aside views of a particular case, but not appropriate to set aside the lens the juror views the world from.  Further, the Chief noted that the trial judge’s questions about the juror working with low income individual wrongly implied that the juror would have to set aside her world views.

Although the case was decided against the defendant, the concurring opinion gives trial courts guidance and a limitation on excluding jurors in similar situations and Massachusetts criminal lawyers a qualification to the opinion to raise to the court in future cases.

To read more about this case Shira Schoenberg of Mass live wrote an excellent account of the case.

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