Wofford v. Woods, No. 18-2367 (6th Cir. 2020)Annotate this Case
Wofford was found guilty of a 1993 murder in a Michigan court following the removal and replacement of a juror. While that juror was holding out against conviction at the time, the judge removed her for misconduct: she had violated his instructions not to discuss the case with anyone other than her fellow jurors by hiring a lawyer to address the court about tensions in the jury room. The Michigan Court of Appeals affirmed Wofford’s conviction under a state precedent on juror removal.
A federal district court granted Wofford’s petition for a writ of habeas corpus, finding that decision not entitled to deference under the Anti-Terrorism and Effective Death Penalty Act, 28 U.S.C. 2254, because the Michigan court had overlooked Wofford’s Sixth Amendment claims and the removal of the juror violated Wofford’s Sixth Amendment rights.
The Sixth Circuit reversed. The 2020 Supreme Court decision, “Ramos,” held that the right not to have a juror removed due to the juror’s opinions on the merits of the case is contained in the Sixth Amendment’s guarantee of a “trial by an impartial jury.” Michigan did not overlook Wofford’s Sixth Amendment claims. While the juror was a holdout, she was not removed for this reason, but because of her misconduct. The Michigan court was free to require a showing of an actual constitutional violation and clearly, if implicitly, did so.