Smith v. Phillips
United States Supreme Court
455 U.S. 209 (1982)
Relevant factsFree
After Phillips (defendant) was convicted of murder, he learned that a sitting juror had applied for an investigator job with the same District Attorney's office prosecuting the case; the federal district court, though finding insufficient evidence of actual bias, imputed bias and reversed the conviction pending a new trial, and the court of appeals affirmed.
IssueFree
Whether, when a convicted criminal defendant raises post-conviction claims of juror bias, a hearing to determine actual bias is the appropriate remedy to safeguard the defendant's due process rights.