Joseph R. Jackson v. United States

Summary

The District of Columbia Circuit held that the presence of a juror who likely had been involved in an affair with a woman later killed by her husband created a presumption of partiality in the defendant's murder trial. The court reversed the convictions and denial of a new-trial motion and remanded for a new trial, while upholding the exclusion of photographs of the deceased.

Holdings

1. A juror's likely involvement in a strikingly similar domestic relationship and homicide created a presumption that he lacked the impartiality required by the Sixth Amendment and required a new trial, despite the absence of a voir dire question precisely identifying the experience.
2. The trial court did not abuse its discretion by excluding photographs depicting Jackson's former wife as an exotic dancer because the photographs had little, if any, relevance and risked inflaming the jury.

Questions Presented

1. Whether juror Kemper's likely prior affair with a woman killed by her husband created a presumption of partiality and denied Jackson his Sixth Amendment right to trial by an impartial jury.
2. Whether the trial court abused its discretion by excluding photographs depicting Jackson's former wife as an exotic dancer.

Disposition

reversed_and_remanded