Turner v. Louisiana

In Turner v. Louisiana, 379 U.S. 466 (1965), the two principal witnesses for the prosecution were deputy sheriffs who had investigated the murder for which the defendant in the case was ultimately convicted and sentenced to death. (Turner, supra, 379 U.S. at p. 466.) The defendant had confessed the crime to these deputies. (Id. at pp. 466-467.) The deputies also acted as bailiffs during the defendant's trial, and the jurors, who were sequestered, were continuously in their presence. (Id. at pp. 467-468.) After the deputies gave their testimony, they continued acting as bailiffs during the trial. (Id. at p. 470.) The Supreme Court concluded that "what happened in this case operated to subvert the basic guarantees of trial by jury," emphasizing that the deputies' testimony "was not confined to some uncontroverted or merely formal aspect of" the prosecution's case. (Turner, supra, 379 U.S. at p. 473.) The high court went on to explain that "even if it could be assumed that the deputies never did discuss the case directly with any members of the jury, it would be blinking reality not to recognize the extreme prejudice inherent in this continual association throughout the trial between the jurors and these two key witnesses for the prosecution." (Ibid.) The court emphasized that the defendant's "fate depended upon how much confidence the jury placed in these two witnesses." (Id. at p. 474.) The United States Supreme Court in held that the defendant's right to a fair trial was violated by the fact that two deputy sheriffs who were key witnesses for the prosecution had charge of the jury during the defendant's three-day trial. The Supreme Court stated: "'In essence, the right to jury trial guarantees to the criminally accused a fair trial by a panel of impartial, "indifferent" jurors. The failure to accord an accused a fair hearing violates even the minimal standards of due process.'" 379 U.S. at 471-72. In Turner, the jurors were sequestered during a three-day trial. The deputy sheriffs "drove the jurors to a restaurant for each meal, and to their lodgings each night [and] ate with them, conversed with them, and did errands for them." 379 U.S. at 468. The Supreme Court held that this arrangement constituted a close and continual association between the deputy sheriffs and the jurors.