Petition for Writ of Certiorari — Eddie Albert Crawford v. Georgia

ORIGINAL

86-6U0:

Supreme Court. U.S.

No. 88 - FILED

DEC 01 1988

IN THE

JOSEPH F. SPANIOL. UR.

SUPREME COURT OF THE UNITED STATES Cusmx

October Term, 1988

EDDIE A. CRAWFORD,

Petitioner,

_— Vv.

STATE OF GEORGIA, (

Respondent.

PETITION FOR WRIT OF CERTIORARI TO THE SUPREME COURT OF GEORGIA

— COURT, Us. GARY A. ALEXION

Georgia Appellate Practice and

Educational Resource Center

GSU College of

Law

University Plaza

Atlanta, Georgia 30303

(404) 651-2898

ATTORNEY FOR PETITIONER

Whether the decision below, denying a change in venue in a

death penalty case because a fair trial was not “impossible,”

violates due process; and, if so, what are the minimal due process

requirements for state change of venue standards in capital cases.

QUESTION PRESENTED... ++ ese ese eeeseeesevense ene eo of

TABLE OF AUTMORITIES . .-. © se ee eee ese ese seo 0 « « ohh

GiGmeew Geeeewe wc esc eee eee ee eee seeee ee ee eo ok

JURISDI CTION . . . . . . . . . . . . . . . . . . . . . . . . . . 1

TIMELINESS OF FILING > . . * * . . . * >. . * . . . . . . . . . * 2

CONSTITUTIONAL PROVISIONS INVOLVED... .. «© «© «© «© © © © «© « «3

i eee ae a a ee a ee ee ee

A. Course of Proceedings . . ce ee eee . -3

B. Facts Relevant to the Question Presented. 3

REASON FOR GRANTING THE WRIT

I.

THE GEORGIA RULE PRECLUDING A CHANGE

OF VENUE IN A DEATH PENALTY CASE

UNLESS A FAIR TRIAL IS “IMPOSSIBLE”

VIOLATES DUE PROCESS AND THIS COURT

SHOULD ESTABLISH MINIMAL DUE PROCESS

REQUIREMENTS FOR STATE CHANGE OF VENUE

STANDARDS IN CAPITAL CASES. ............. .6

A. Lack of a Clear Standard in this Court's Cases . 6

B. The State's Standards. ...... ?

C. The Need for Resolution of the Issue . 9

D. The Need for Resolution of the Issue

im Beeth Bemalty Gages... - ss se se ee ee 20

ee «6 6 6h 8G So eS 6a Oe 6 4 oe 0 SS See

APPENDIX A - Opinion of the Supreme Court of Georgia in

, 257 Ga. 681, 362 S.E.2da 201

(1987).

ii

TABLE OF AUTHORITIES

Cases

Booth v. Maryland, 482 U.s.__

Brecheen v. Oklahoma, 108 S.Ct. 1085 (1988)

, 107 S.Ct. 2529 (1987).

Chancey v. State, 256 Ga. 415, 349 S.Ed.2d 717 (1986).

, 489 Pa. 167, 413 A.24a

cert. denied, 449 U.S. 840 (1980) ...

Crawford v. State, 257 Ga. 681, 201 (1987) .

Dobbert v. Florida, 432 U.S. 282 (1977)...

Estes v. Texas, 381 U.S. 32 (1965). ....

Greag v. Georgia, 428 U.S. 153 (1976)... .

Groppi v. Wisconsin, 400 U.S. 505 (1971) . .

In_re Murchison, 349 U.S. 133 (1955) ....

Irvin v. Dowd, 366 U.S. 717 (1961) .....

,» 29 Cal.3d 574, .

174 Cal.Rptr. 701, 629 P.2d 502 (1981)

Mooney v. State, 243 Ga. 373, 254 S.E.2d 337

Murphy v. Florida, 421 U.S. 794 (1975) ...

Patton v. Yount, 467 U.S. 1025 (1984). ...

People v. Gendron, 41 Ill.2d 351, 243 N.E.2d

Rideau _v. Louisiana, 373 U.S. 723 (1963) ..

Sheppard v. Maxwell], 384 U.S. 333 (1966) ..

State v. Biegenwald, 106 N.J. 13, 524 A.2d 130

State v. Cuevas, 288 N.W.2d 525 (Iowa 1980).

State v. Link, 640 P.2d 366 (Mont. 1981) . .

1066,

State v. Pease, 740 P.2d 659 (Mont. 1987). .....

State v. Williams, 93 N.J. 39, 459 A.2d 641 (1983) .

(1976)

Tumey v. Ohio, 272 U.S. (1927) . . 2. 2. «© we we we wee

Witherspoon v. Illinois, 391 U.S. 510 (1968) ....

Woodson v. North Carolina, 428 U.S. 280 (1978) ...

Street vy. State, 237 Ga. 307, 227 S.E.2d 750,

iii

(1987).

—_— a

Constitutional and Statutory Provisions

8. Constitution Amendment VIII .* .* * * . * * * . . . .* * * 3,10

U.S. Constitution Amendment XIV ......+ +++ «© «© «© « 03,6

at oe nn ne » «e604 e¢ eee eeseenvse 6 & » of

Other Authorities

o

ABA Standards Relating to Fair Trial and Free Press 8-3. o—

(24 ed. Approved Draft (1978)).....++es-s. -8,9

ABA Standards Relating to Fair Trial and Free —

8-3.3(c) (24 ed. Approved Draft (1968).

iv

No. 88 -

IN THE

SUPREME COURT OF THE UNITED STATES

October Term, 1988

EDDIE A. CRAWFORD,

Petitioner,

- Vv.-

STATE OF GEORGIA,

Respondent.

PETITION FOR WRIT OF CERTIORARI TO THE SUPREME COURT OF GEORGIA

Petitioner, Eddie A. Crawford, respectfully prays that a writ

of certiorari issue to review the judgment and decision of the

Supreme Court of the State of Georgia entered on the 19th day of

November 1987, which affirmed petitioner's death sentence.

OPINION BELOW

The opinion of the Supreme Court of the State of Georgia is

reported as Crawford v. State, 257 Ga. 681, 362 S.E. 2d 201 (1987),

and is annexed hereto as Appendix A.

JURISDICTION

The judgment and order of the Supreme Court of Georgia were

entered on November 19, 1987. A timely filed petition for

rehearing was denied on December 16, 1987. The jurisdiction of

this Court is invoked pursuant to 28 U.S.C. Section 1257(3),

petitioner asserting a deprivation of his rights secured by the

United States _—

TIMELINESS OF FILING

Petitioner is an indigent inmate under sentence of death. He

was represented at trial and in the court below by an attorney

retained by members of his family. Petitioner last spoke with this

attorney, Mr. August F. Siemon, III, of Atlanta, Georgia, before

the case was decided by the Supreme Court of the State of Georgia

on November 19, 1987. Mr. Siemon never advised petitioner that he

would not continue to represent him after the final decision of the

Supreme Court of the State of Georgia.

On or about October 1, 1988, the Georgia Appellate Practice

and Educational Resource Center, with which undersigned counsel is

associated, commenced operations. This organization was founded

by the State Bar of Georgia to ensure that all inmates under

sentence of death in Georgia are represented by counsel in post-

conviction proceedings.

In early October 1988, the personnel of the Georgia Appellate

Practice and Educational Resource Center, including undersigned

counsel, became aware o. petitioner's case and of the fact that

petitioner seemed to have no current counsel. On October 14, 1988,

undersigned counsel visited petitioner at his place of confinement,

the Georgia Diagnostic and Classification Center in Jackson,

Georgia. At that time petitioner indicated that he wanted the

instant petition filed on his behalf and that he wanted undersigned

counsel to represent hin. Thereafter, undersigned counsel

communicated with Mr. Siemon and, on October 21, 1988, received

the trial record, transcript and other relevant documents.

From December 16, 1987 through October 14, 1988, petitioner

was effectively without counsel. Moreover, during this period

petitioner was unaware of the fact that his previous attorney was

not continuing to represent him.

Although this petition is filed after the expiration of the

time prescribed in Rule 20.1, petitioner respectfully requests,

for the reasons set forth above, that this Court waive the time

requirements in the interests of justice.

CONSTITUTIONAL PROVISIONS INVOLVED

This case involves the eighth amendment to the United States

Constitution, which provides that:

Excessive bail shall not be required, nor excessive fines

imposed, nor cruel and unusual punishments inflicted;

and the fourteenth amendment to the United States Constitution

which provides in relevant part:

[Njor shall any state deprive any person of life,

liberty, or property, without due process of law; nor

deny to any person within its jurisdiction the equal

protection of the laws.

STATEMENT OF THE CASE

A. Course of Proceedings

Petitioner was indicted for murder in the death of Leslie

Michelle English, which occurred on September 25, 1983. He was

convicted of murder on March 7, 1984 and sentenced to death on

March 8, 1984. On May 31, 1985, the Supreme Court of Georgia

reversed the conviction and sentence on the ground that the guilty

verdict did not specify whether the jury had found defendant guilty

of malice murder or felony murder and that under the then existing

indictment a conviction of felony murder could not stand. Crawford

v. State, 254 Ga. 435, 330 S.E. ‘2d 567 (1985).

Petitioner was thereafter indicted for felony murder, for the

same alleged acts, and convicted of that offense on February 5,

1987. He was sentenced to death on February 6, 1987.

The Supreme Court of Georgia affirmed the conviction and

sentence on direct appeal on November 19, 1987. Crawford v. State,

257 Ga. 681, 362 S.E. 2d 201 (1987).

B. Facts Relevant to the Question Presented

Petitioner's retrial commenced on January 26, 1987. At voir

dire, it quickly became apparent that a substantial number of the

potential jurors knew that there had been a previous trial. Many

of these knew either that the petitioner had been found guilty or

that he had received a death sentence, or both.

In anticipation of this, petitioner's trial counsel had filed

a motion for change of venue, which was denied by the court at

trial. T. 1126.'

Additionally, during voir dire, petitioner's trial counsel

objected to the seating of any juror who had knowledge of the prior

proceeding. This too was denied. T. 230-31.

An examination of the transcript of the voir dire reveals the

true extent to which the venire was tainted by the knowledge of the

prior trial. Of a panel of 90 potential jurors, 78 were asked

specifically whether they were aware of any prior proceedings in

petitioner's case. Of these, 57 (74%) indicated that they knew

about the prior trial. Of the 78, 50 (64%) indicated that they

knew that a previous jury had adjudged the petitioner guilty; 32

of them (41%) indicated that they knew that the prior jury had

determined that a death sentence was appropriate.

Of the 78 jurors who were asked about the previous trial, 29

were excused for cause. Arguably, it is the remaining group of 49

which should be scrutinized to determine the extent of the taint.

Performing the calculations with respect to this smaller pool,

however, indicates no significant diminishment of the taint: 33 of

them (67%) knew of the prior trial; 29 (59%) knew of the prior

adjudication of guilt; and 19 (39%) knew of the prior imposition

of a death sentence.’

Counsel for petitioner used all of his peremptory challenges

in selecting the jury. Nonetheless, a substantial number of the

jurors who heard and decided the case knew about the prior

proceedings in some way: eight knew about the prior trial; five

‘Numerals preceded by "T." refer to the transcript of trial,

held January 26 through February 6, 1987.

*puring the voir dire, petitioner's counsel was forced into a

delicate situation in questioning jurors who did not know about the

prior proceeding. On the one hand, he did not want to taint the

minds of the jurors who did not know about the prior trial, so he

avoided asking these members of the venire what their reaction

would be if and when they found out about it. At the same time,

he was concerned that if a jury was chosen that consisted partly

of persons who knew and partly of persons who did not, discussions

amongst them would give rise to a taint which would not thereafter

be discoverable. T. 230-31.

also knew about the prior adjudication of guilt and three knew that

the prior jury had set the punishment of death. In fact, the jury

foreman, who knew about the trial and adjudication of guilt, was

selected after petitioner's counsel had exhausted his peremptory

challenges.

On direct appeal, petitioner contended, jnter alia, that the

trial court erred in not granting the motion for a change of venue.

This argument was rejected by the Supreme Court of Georgia on the

grounds that the petitioner had not shown during voir dire that a

fair trial was “impossible.” Crawford v. State, 257 Ga. 681, 683,

362 S.E.2d 201, 203 (1987).

REASON FOR GRANTING THE WRIT

I. THE GEORGIA RULE PRECLUDING A CHANGE OF VENUE IN A DEATH PENALTY

CASE UNLESS A FAIR TRIAL IS “IMPOSSIBLE” VIOLATES DUE PROCESS AND

THIS COURT SHOULD ESTABLISH MINIMAL DUE PROCESS REQUIREMENTS FOR

STATE CHANGE OF VENUE STANDARDS IN CAPITAL CASES.

This Court has long recognized that "[{a) fair trial in a fair

tribunal is a basic requirement of due process." Jn re Murchison,

349 U.S. 133, 133 (1955). To comport with this due process

requirement, a jury trial must be before "a panel of impartial,

‘indifferent' jurors." Irvin v. Dowd, 366 U.S. 717, 722 (1961).

Thus, a refusal to change the venue of a trial where the accused

has demonstrated even potential jury predisposition against him can

violate the due process clause of the fourteenth amendment to the

United States Constitution. See, e.g., Rideay v. Louisiana, 373

U.S. 723 (1963); Sheppard v. Maxwell], 384 U.S. 333 (1966).

Petitioner here showed that a vast proportion of the venire

knew of his prior trial and prior death sentence for the same

crime. Nevertheless, the Georgia Supreme Court denied petitioner's

motion for a change of venue on the grounds that petitioner's

evidence did not establish actual jury prejudice "to a degree that

rendered a fair trial jmpossible." Crawford v. State, 257 Ga. 681,

683, 363 S.E.2d 201, 203 (1987) (emphasis added). The Georgia

standard -- allowing for a change of venue only where an accused

can show thet a fair trial is “impossible” -- is only one of

numerous standards enunciated by state courts around the country.

This Court should grant the writ to establish clear constitutional

limits on state change of venue standards in light of the "vacuum

of constitutional precedent" in this important area. Brecheen v.

Oklahoma, 108 S.Ct. 1085, 1086 (1988) (Marshall, J., dissenting

from denial of certiorari).

A. Lack of a Clear Standard in this Court's Cases

This court has rendered numerous decisions involving changes

of venue due to jury predisposition. See, e.g., Patton v. Yount,

467 U.S. 1025 (1984); Dobbert v. Florida, 432 U.S. 282 (1977);

Murphy v. Florida, 421 U.S. 794 (1975); Sheppard v. Maxwell], 384

U.S. 333 (1966); Rideau v. Louisiana, 373 U.S. 723 (1963); Irvin

v. Dowd, 366 U.S. 717 (1961). But in each of these cases, the

6

Court has examined only whether changes of venue are

constitutionally mandated in the factual circumstances of specific

trials. See id.; Brecheen v. Oklahoma, 108 S.Ct. at 1086

(Marshall, J., dissenting from denial of certiorari). The Court

has “had little occasion to apply these basic principles to

determine whether particular state standards for change of venue

comport with the requirements of due process." Jd. at 1086.

On one occasion, this Court did find that a state statute

regulating venue changes violated due process. In Groppi v.

Wisconsin, 400 U.S. 505 (1971), the Court struck down a Wisconsin

rule denying changes of venue in all misdemeanor cases. Aside from

this, however, states have been afforded no guidance in deve) oping

standards for changes of venue which ensure that due process is not

violated.

B. The State Standards

As a result of the “vacuum of constitutional precedent” on

due process requirements for state change of venue standards,

states have adopted a wide variety of change of venue rules.

Brecheen v. Oklahoma, 108 S.Ct. at 1086 (Marshall, J., dissenting

from denial of certiorari). In some states, venue must be changed

whenever “there is a reasonable likelihood that in the absence of

such relief, a fair trial cannot be had." Martinez v. Superior

Court, 29 Cal.3d 574, 577-78, 174 Cal. Rptr. 701, 702, 629 P.2d

502, 503 (1981); accord State v. Cuevas, 288 N.W.2d 525 (Iowa

1980); Waukazo v. State, 269 N.W.2d 373 (Minn. 1978). The Martinez

court interprets the phrase "reasonable likelihood" as "“denot([ing)

a lesser standard of proof than ‘more probable than not.'"

Martinez, 29 Cal.3d at 578, 174 Cal. Rptr. at 702, 629 P.2d at 503.

Other states will grant venue changes only if there are

“reasonable grounds to believe that the prejudice alleged actually

exists" and a “reasonable apprehension” that the prejudice would

prevent a fair trial. People v. Gendron, 41 I11.2d 351, 243 N.E.2d

208, 211 (1968); accord State v. Pease, 740 P.2d 659 (Mont. 1987).

This standard is higher than the “reasonable likelihood” rule.

State v. Link, 640 P.2d 366, 368 (Mont. 1981). At least one state

has adopted a standard requiring a “realistic likelihood of

prejudice." State v. Biegenwald, 106 N.J. 13, 33, 524 A.2a 130,

140 (1987).

Still other states require a "gubstantia]l likelihood” that a

fair trial cannot be had before a motion for change of venue must

be granted. See, ¢.g., Commonwealth v. Cohen, 489 Pa. 167, 178,

413 A.2d 1066, 1072, cert. denied, 449 U.S. 840 (1980). The ABA

endorses the “substantial likelihood" rule in its Standards

Relating to Fair Trial and Free Press 8-3.3(c) (2d ed. Approved

Draft, 1978).

In Georgia, however, a motion for a change of venue based upon

actual juror predispositions will not be granted unless the accused

can show “prejudice to a degree that rendered a fair trial

impossible.” Chancey v. State, 256 Ga. 415, 430, 349 S.E.2d 717,

730 (1986); Street v. State, 237 Ga. 307, 311, 227 £.E.2d 750, 754

(1976) .?

The Supreme Court of Georgia affirmed the denial of

petitioner's motion for a change of venue because he did not meet

this stringent test. Crawford vy. State, 257 Ga. 681, 683, 362

S.E.2d 201, 203 (1987).

The Georgia standard is higher even than the Oklahoma

threshold for change of venue condemned in Brecheen vy. Oklahoma,

108 S.Ct. 1085 (Marshall, J., dissenting from denial of

certiorari). In Oklahoma, venue will not be changed unless the

accused presents "'clear and convincing evidence’ that a fair trial

is a ‘yirtual impossibility’". id. at 1086 (emphasis added).

Justice Marshall, joined by Justice Brennan, found that Oklahoma's

venue change standard “failfed] to accommodate properly the

concerns expressed in (this Court's} due process precedents." Jd.

at 1087.

The conflict and confusion among the states about the proper

standard for venue changes is evidenced by shifts in state

3Georgia has explicitly refused to adopt the lesser

“reasonable likelihood" standard, even when that rule was endorsed

in the ABA Standards Relating to Fair Trial and Free Press. Mooney

vy. State, 243 Ga. 373, 386, 254 S.E.2d 337, 347 (1979).

fm

standards. Montana, which had required a showing of “prejudice

substantial enough to make a fair trial impossible," switched

abruptly in 1981 to a rule requiring only “reasonable grounds to

believe that the prejudice alleged actually exists" and a

“reasonable apprehension" that the prejudice would prevent a fair

trial. State v. Link, 640 P.2d 366, 368 (Mont. 1981). In New

Jersey, the standard changed from a requirement of "clear and

convincing proof that a fair and impartial trial cannot be had" to

allowing venue changes “where it is ‘necessary to overcome the

realistic likelihood of prejudice.'" State v. Biegenwald, 106 N.J.

13, 33, 524 A.2d 130, 139-40 (1987), citing State vy. Williams, 93

N.J. 39, 67-68 n.13, 459 A.2d 641, 656 n.13 (1983). Even the ABA

has changed its recommended standard from the “reasonable

likelihood" rule to the “substantial likelihood" rule. Compare,

ABA Standards Relating to Fair Trial and Free Press 3.2(c) (1968)

with ABA Standards Relating to Fair Trial and Free Press 8-3.3(c)

(1978).

C. The Need for Resolution of the Issue

The strict Georgia venue’change standard -- denying changes

in venue unless prejudice has rendered a fair trial "impossible"

-- violates all precepts of due process. This Court has enunciated

various thresholds for examining questions of due process, none of

which even approaches the strict "impossibility" standard adopted

in Georgia. For example, the Court has repeatedly recognized that

“our system of law has always endeavored to prevent even the

probability cf unfairness." In re Murchison, 349 U.S. 133, 136

(1955) (emphasis added); gee also Sheppard v. Maxwell, 384 U.S.

333, 352 (1966); Estes vy. Texas, 381 U.S. 532, 544-45 (1965). The

Court has also stated that "(e)very procedure which would offer a

possible temptation to the average man... to forget the burden

of proof required to convict the defendant, or which might lead him

not to hold the balance nice, clear and true between the State and

the accused, denies the latter due process of law." Tumey v. Ohio,

273 U.S. 510, 532 (1927) (emphasis added); gee also Irvin v. Dowd,

366 U.S. 717, 722 (1961); Estes v. Texas, 381 U.S. at 543.

Petitioner here clearly established the likelihood that the

jury in his case would not “hold the balance nice, clear and true

between the State and the accused." Almost 75% of the venire who

were asked knew that he had been tried before for the same crime.

Of those asked about the verdict and sentence in the previous

trial, 64% knew that petitioner had been found guilty and 41% knew

that he had been sentenced to death. Yet because he could not show

that this vast knowledge among the venire made a fair trial

“impossible,” petitioner was denied a change of venue under Georgia

law.

D. The Need for Resolution of the Issue in Death Penalty Cases

That petitioner may have been tried by a jury with “such fixed

opinions that they could not judge impartially," Patton v. Yount,

467 U.S. 1025, 1035 (1984), is even more troubling given that this

is a death penalty case. This Court has long recognized, under the

eighth amendment to the United States Constitution, a heightened

need for reliability in cases involving the death penalty. Woodson

v. North Carolina, 428 U.S. 280, 305 (1978). “When a defendant's

life is at stake the Court has been particularly sensitive to

insure that every safeguard is observed." Gregg vy. Georgia, 428

U.S. 153, 187 (1976).

Moreover, in death penalty cases the jury undertakes a unique

role in the sentencing phase: to “express the conscience of the

community on the ultimate question of life or death." Witherspoon

vy. Illinois, 391 U.S. 510, 519 (1968). In no other area of

jurisprudence does the jury make such a momentous decision. For

this reason, the Court has recognized the need for special

procedural safeguards to avoid the “unacceptable risk that the jury

may impose the death penalty in an arbitrary and capricious

manner." Booth v. Maryland, 482 U.S. __, 107 S.Ct. 2529, 2533

(1987); gee also Gregg vy. Georgia, 428 U.S. 153, 189 (1976). In

petitioner's case, jurors knew of his previous trial and prior

death sentence for the same crime. That knowledge created an

"unacceptable risk" that for the crucial life-or-death decision in

the sentencing phase of his trial, petitioner did not have the

10

“panel of impartial, ‘indifferent' jurors" guaranteed by the due

process clause of the United States Constitution. Irvin y. Dowd,

366 U.S. 717, 722 (1961).

CONCLUSION

For the foregoing reasons, the petition for a writ of

certiorari should be granted.

Respectfully submitted,

Georgia llate Practice and

Educational Resource Center

GSU College of Law

University Plaza

Atlanta, Georgia 30303

(404) 651-2898

ATTORNEY FOR PETITIONER

il

IN THE SUPREME COURT OF THE UNITED STATES

October Term, 1968

EDDIE ALBERT CRAWFORD

Petitioner,

-Vv-

STATE OF GEORGIA,

Respondent.

CERTIFICATE OF SERVICE

I hereby certify that I have served a copy of the foregoing

Petition for Writ of Certiorari to the Supreme Court of Georgia

upon Respondent by hand, addressed as follows:

Eddie Snelling, Jr. Esq.

Senior Assistant Attorney General

132 State Judicial Building

40 Capitol Square, $.W.

Atlanta, Georgia 30334

This the JO day of _AJevembe- _. 1988.

Qh Bia in

ATTORNEY FOR PETITIONER

APPENDIX “A

CRAWFORD v. STATE Ga. 201

was telling him an untruth to obtain the

warrant somehow makes it alight, is ridic-

faith” rule to magistrates when they are

told an untruth so as to “cure” the officer's

untruthful statement? I pray not.

Reconsideration Denied Dec. 16, 1987.

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