Case Summary: U.S. Supreme Court (Jan. 21, 2025)

This post summarizes a criminal law decision published by the U.S. Supreme Court on Jan. 21, 2025. Due process protection against highly prejudicial and irrelevant evidence was clearly established; denial of habeas petition reversed Andrew v. White, 604 U.S. ___; ___ S. Ct. ___; 2025 WL 247502 (Jan. 21, 2025) (per curiam). The petitioner was convicted of first-degree murder in Oklahoma state court and sentenced to death. She was allegedly a part of a conspiracy to murder her estranged husband, along with a man she was dating at the time and another person. The boyfriend eventually confessed that he and another man had killed the victim but denied that the petitioner was involved in the crime. That man was also convicted of the murder and sentenced to death. During the petitioner’s trial, the State presented a voluminous amount of irrelevant and salacious evidence relating to the petitioner’s private life. Among other things, the prosecution elicited testimony about Andew’s sexual partners reaching back two decades; about the outfits she wore to dinner or during grocery runs; about the underwear she packed for vacation; and about how often she had sex in her car. At least two of the prosecution guilt-phase witnesses took the stand exclusively to testify about Andrew’s provocative clothing, and others were asked to comment on whether a good mother would dress or behave the way Andrew had. In its closing statement, the prosecution again invoked these themes, including by displaying Andrew’s ‘thong underwear’ to the jury, by reminding the [...]