Minute Summary
Brenda Andrew was found guilty of murdering her husband and sentenced to death. She later argued that the trial was unfair because the prosecution focused their argument too much on her personal life rather than the actual crime. For instance, the prosecution brought up her past relationships and her dressing tendencies. The lower courts rejected her claim, saying there was no clear law or precedent that proved this was a problem. But the Supreme Court disagreed, saying there was a legal rule against unfair trials caused by overly prejudicial evidence. The Court sent the case back for further review.
Important Definitions
Due Process Clause: A rule in the Constitution that ensures people get fair trials.
Prejudicial Evidence: Information that makes someone look bad rather than helping prove if they did something wrong.
Habeas Corpus: A legal process by which someone in prison argues that their punishment was unfair or unwarranted.
AEDPA (Antiterrorism and Effective Death Penalty Act): A law that makes it harder for federal courts to change state court decisions in criminal cases, needing to identify “clearly established federal law governing a claim" to prove said claim.
Harmless Error: A mistake in court that doesn’t change or have a determining impact in the final decision.
Extended Summary
In Andrew v. White, the Supreme Court looked at whether Brenda Andrew’s trial was unfair. Andrew was convicted of plotting with her boyfriend to kill her husband for insurance money. But instead of focusing only on the crime, the prosecutors spent a lot of time talking about her personal life; they brought up things like what she wore, who she dated, and even the type of underwear she packed for a trip. Andrew claimed this was unfair because it made the jury judge her for her lifestyle choices instead of the alleged crime. She argued that because these unrelated pieces of evidence were brought up in trial the jury was never afforded the opportunity to judge the case on its merit; rather, Andrew claimed, the jurors were asked to judge someone whom they had already established a negative perception of.
The Oklahoma Court of Criminal Appeals admitted that some of this evidence wasn’t important to the case. However, they still upheld her conviction, saying there was plenty of other proof that she was guilty, and that the supposedly prejudicial evidence was "harmless." When Andrew appealed again, a lower federal court agreed, saying that there was no clear Supreme Court rule that established a precedent that prejudicial evidence could make a trial unfair.
The Supreme Court disagreed, however, ruling that the claim that there was no precedent or previous ruling is wrong. The court pointed out that previous cases had already made it clear that if a trial is too unfair because of prejudicial evidence, it can violate someone’s right to due-process. Since the lower court didn’t consider whether Andrew’s trial was unfair because of this, the Supreme Court sent the case back for another review.
It is so ordered.
Think of It Like This
Imagine a student, Brenda, is accused of cheating on a test. Instead of just looking at the cheating, the teacher brings up unrelated things about how she wears bright clothes, talks loudly, and never does her homework. The principal argues that this makes her a bad student overall. Brenda says that’s unfair because she should only be judged on whether or not she cheated on the test. If the other comments made the schools administration dislike her more than they otherwise would have, the punishment might not be fair, taking away her right to due-process. Thus, the Supreme Court ruled that the school must take another look at whether Brenda was judged unfairly as a result of the unrelated, prejudicial evidence brought up by the teacher.
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