United States of America ex rel. Silvio De Vita v. Lloyd W. McCorkle, Principal Keeper of the New Jersey State Prison at Trenton, New Jersey

Summary

The Third Circuit held that a state prisoner was entitled to habeas corpus relief because a juror concealed a recent robbery experience and possible connections with law-enforcement personnel during voir dire. The court concluded that these undisputed circumstances demonstrated sufficient potential bias to undermine the constitutional requirement of an impartial tribunal, particularly in a capital case. The district court's orders were reversed and the case was remanded for issuance of the writ, with the possibility of a new trial limited to sentencing if permitted by New Jersey law.

Holdings

1. In a capital case, the undisputed circumstances of Kuhnle's recent armed-robbery victimization, his failure to disclose it during voir dire, and the similarity between his experience and the charged offense demonstrated bias sufficient to invalidate the process and deny De Vita a fundamentally fair trial.
2. The state courts did not give fair and satisfactory consideration to the portions of De Vita's prejudice claim concerning Kuhnle's relationship with local law-enforcement personnel and the resulting possibility of bias.
3. The writ of habeas corpus should issue; if New Jersey law permitted retrial on the sentence alone, relief could be limited to a new sentencing proceeding, otherwise a general new trial was required.

Questions Presented

1. Whether the participation of a juror who had recently been the victim of a similar armed robbery and failed to disclose that fact during voir dire rendered De Vita's trial fundamentally unfair under the Due Process Clause.
2. Whether the state courts and federal district court adequately considered De Vita's claim that Kuhnle was biased and had falsely denied knowing personnel connected with the prosecution.
3. What habeas relief was appropriate after the constitutional defect in the jury was established.

Disposition

reversed_and_remanded