Free Press v. Fair Trial: Supreme Court Decisions since 1807

By Douglas S. Campbell | Go to book overview

Holt v. U.S.

James H. Holt v. The United States Docket No. 1910-231 218 U.S. 245, 54 L.Ed. 1021, 31 S.Ct. 2 ( 1910) Argued October 13 and 14, 1910. Decided October 31, 1910.


Background

By the beginning of the twentieth century the Court had clearly established the notion that prospective jurors who had formed an opinion about the guilt of an accused were not necessarily unconstitutionally prejudiced. If they were able to change their minds and arrive at a verdict based on only evidence admitted into court, then they were considered competent. If their impressions of guilt or innocence were too deep to be changed by the evidence, however, then they were considered partial and so incapable of rendering a fair verdict.

The Court had also clearly established the notion that a trial judge was competent to determine the fact of unconstitutional prejudice, mainly because the judge could observe the demeanor of jurors while they were declaring their impartiality (see Hopt v. Utah [ 1887]). An appellate court, therefore, was not to overrule trial judges unless they made a "manifest" or clear error in fact when determining partiality (see Reynolds v. U.S. [ 1878]). Justice Oliver Wendell Holmes, Jr., strongly reaffirmed here the Court's continued confidence in jurors to arrive at an impartial verdict even though they may have formed an opinion from reading a newspaper and its confidence in the trial judge's ability to evaluate the impartiality of prospective jurors.


Circumstances

On May 8, 1908, James H. Holt killed Henry E. Johnson by striking him on the head three times with an iron bar known as a fish plate. Both men were soldiers in the Coast Artillery Corps of the U.S. Army, stationed at the Fort Warden Military Reservation on the northwestern coast of Puget

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