Andrew v. White, , was a United States Supreme Court case in which the court vacated and remanded the decision of the United States Court of Appeals for the Tenth Circuit, holding that, as established in Payne v. Tennessee, the Due Process Clause forbids the introduction of evidence so unduly prejudicial as to render a criminal trial fundamentally unfair.
Background
An Oklahoma jury convicted Brenda Andrew of murdering her husband and sentenced her to death. At trial, the State had introduced substantial evidence "about Andrew’s sex life and about her failings as a mother and wife," which the State later admitted to be irrelevant. Andrew argued in federal court that that evidence was so prejudicial that it was a violation of the Due Process Clause. A federal district court denied her habeas corpus petition and the United States Court of Appeals for the Tenth Circuit affirmed that decision, reasoning that Payne v. Tennessee had made a "pronouncement" but not a holding of “clearly established federal law governing her claim.”
Opinion of the Court In a per curiam decision, the Supreme Court held that the legal argument relied upon by Andrew was "indispensable to the decision in Payne." Therefore, it was a holding of the Supreme Court and the petitioner had "properly identified clearly established federal law" that must be followed when ruling on her habeas petition.
Dissent Justices Thomas and Gorsuch dissented. They reasoned that the petitioner's legal argument was based on "a one-sentence aside" in Payne and that the majority opinion "redefines 'clearly established' law to include debatable interpretations of [Supreme Court] precedent."
Later developments On remand, the Tenth Circuit reaffirmed the conviction. The Court found the remaining evidence against Andrews, such as her $800,000 life insurance policy on the victim, a faked gunshot injury to disguise the murder as a robbery, and immediately fleeing with her children to Mexico before the funeral, was so overwhelming they could not find that the jury rendered its verdict because of the improper evidence about her sex life.
See also Murder of Rob Andrew Capital punishment in Oklahoma
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