Petitioner’s courtroom outburst, during which he referred to a prosecution witness, his mother, as an “evil fucking bitch,” and the subsequent instruction by the court that the jury could consider it, was not egregious or prejudicial enough to cause a violation of due process. Petitioner had already confessed to killing the victim, and had argued that he was subject to fits of uncontrollable rage due to childhood abuse. It is unlikely that the jurors thought less of him because of his courtroom outburst.
Case Summaries