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Andrew v. White

In Andrew v. White, the Supreme Court reviewed the Tenth Circuit's decision to reject Brenda Andrew's due process challenge to her conviction for murder. Andrew was charged with murdering her husband -- at trial, the prosecution introduced prejudicial evidence with little probative value to the issue of her guilt. This included her sexual history, personal attire, and alleged failings as a wife and mother. The prosecution further elicited evidence meant to contrast this with her husband's character. On appeal, Andrew alleged that these irrelevant characteristics were meant to improperly impute the murder to her. 

The Tenth Circuit rejected her due process claim, but the Supreme Court disagreed. Though the decision below reasoned that there was no general rule that the wrongful admission of prejudicial evidence violates due process -- the Supreme Court disagreed. Relying on Payne v. Tennessee, the Court clarified that introducing inadmissible prejudicial evidence, may violate the Due Process Clause when it renders the trial fundamentally unfair. So, the case was remanded to the Tenth Circuit to determine whether the prosecution's inflammatory evidence materially affected the outcome of the trial. 

Per curiam decision. Justice Alito concurring. Justice Thomas dissenting. 

Read by RJ Dieken. 

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