Patton v. Yount

In Patton v. Yount (1984) 467 U.S. 1025, the defendant was sentenced to life in state prison for first degree murder and rape. (Id. at p. 1028.) By our computation, 98.8 percent of the venire had heard of the case, and 77 percent of those had fixed opinions about the defendant's guilt that they "would carry ... into the jury box." (Id. at p. 1029.) The Third Circuit granted habeas corpus relief. (Id. at p. 1032.) The United States Supreme Court reversed, because the Court of Appeals had "failed to give adequate weight to other significant circumstances in this case," such as the decrease in publicity over time and the trial court's finding that the jury as a whole was impartial--even though eight of 14 seated jurors and alternates admitted to having reached an opinion of the defendant's guilt at some point in time. (Id. at pp. 1029-1030, 1032.) The Supreme Court held that a trial court's finding that a juror should or should not be disqualified is a finding of historical fact (id. at pp. 1036-1037, fn. 12), and on habeas corpus review for constitutional error the trial judge's own "findings of jurors' impartiality may be overturned only for 'manifest error.'" (Id. at p. 1031.)