The district courts judgment affirming appellants conviction and death sentence was vacated and the case remanded for an evidentiary hearing where the appellate court was unable to make a determination on the claim of juror bias absent an evidentiary hearing. During voir dire, one of the jurors revealed that his wife had been assaulted, beaten, and robbed two years previously, and the attacker had never been caught. He did not reveal that his wife had also been raped, that the assailant was black, or that the assault occurred close to where the rape and murder charged in this case occurred. Declarations obtained in support of the habeas petition also showed that the events had a radical effect on the jurors life, and that he had discussed the Fields trial with his wife, who suspected that Fields might also be her assailant. The appellate court found that since the district court had not addressed the issue of the improper communications, remand and an evidentiary hearing were required.
Case Summaries