White v. Woodall (2013)
- Docket
- 12-794
- Decided
- 2013-01-01
Summary
Question: (1) Did the trial court violate Woodall's Fifth Amendment rights when it refused to provide a "no adverse inference" instruction to the jury in a capital punishment case in which the defendant has pled guilty? (2) Was the trial court's failure to provide a "no adverse inference" instruction a harmless error in light of the overwhelming evidence of guilt that resulted in a guilty plea? Conclusion: No, unanswered. Justice Antonin Scalia delivered the opinion of the 6-3 majority. The Court held that the trial court did not violate Woodall's Fifth Amendment rights by not providing a "no adverse influence" jury instruction because Woodall's guilty plea negated the possibility of any adverse influence. Because Woodall admitted to the elements of the case that the prosecution would otherwise have had to prove, there was no inference left for the jury to make. The Court therefore held that the state courts' rejection of Woodall's Fifth Amendment claim was not objectively unreasonable and should not have proceeded to federal courts. Justice Stephen G. Breyer wrote a dissenting opinion in which he argued that a criminal defendant is entitled to a "no adverse influence" jury instruction at the penalty phase of a capital trial just as he is during the guilt phase if he requests one. Justice Breyer wrote that there was no reason to deviate from established Fifth Amendment jurisprudence on this issue and that, in doing so, the majority opinion construes the precedent too narrowly. Justice Ruth Bader Ginsburg and Justice Sonia Sotomayor joined in the dissent.