Amanda Barbara Nichole Taylor v. Commonwealth of Virginia, 796 S.E.2d 859

Amanda Taylor was convicted of first-degree murder; on appeal she argued the trial court erred by denying a defense motion to strike a prospective juror ("Juror K") for cause.
During group voir dire jurors acknowledged the presumption of innocence and the Commonwealth’s burden; Juror K indicated he had heard about the case.
In individual voir dire Juror K said he was "probably more leaning towards guilty" based on pretrial publicity but repeatedly stated he could set aside any prior opinion and decide the case solely on the evidence.
Defense moved to strike Juror K for cause after Juror K again conceded he had a preconception; the trial judge questioned Juror K, who reaffirmed he could be impartial and follow the court’s instructions.
The trial court denied the motion to strike; the defense used a peremptory challenge to remove Juror K and Taylor was convicted.
On appeal the Court of Appeals reviewed whether the trial court manifestly erred in finding Juror K impartial and affirmed the conviction.

Issue	Taylor's Argument	Commonwealth's Argument	Held
Whether the trial court erred in denying a challenge for cause to a juror who had a pretrial impression of guilt	Juror K’s admission that he was "leaning toward guilty" showed he could not be impartial and should have been struck for cause	Juror K repeatedly and unequivocally stated he could set aside prior impressions and decide the case solely on the evidence; the trial court observed demeanor and credited impartiality	Denied error — trial court did not manifestly err; Juror K’s assurances and demeanor supported retention

Irvin v. Dowd, 366 U.S. 717 (setting standard that jurors need not be totally ignorant but must be able to set aside impressions and decide on evidence)
Justus v. Commonwealth, 220 Va. 971 (discussing constitutional right to an impartial jury and Code § 8.01-357 panel requirement)
Briley v. Commonwealth, 222 Va. 180 (upholding denial of strike for cause where jurors admitted pretrial impressions but declared no fixed opinion and could follow law)
Calhoun v. Commonwealth, 226 Va. 256 (finding no error where jurors affirmed ability to disregard prior knowledge and render verdict on evidence)
Green v. Commonwealth, 262 Va. 105 (reversing where juror’s equivocation showed inability to stand indifferent and apply presumption of innocence)
Smith v. Commonwealth, 219 Va. 455 (trial court must weigh phrasing, inflection, tone, and demeanor when assessing juror impartiality)
Spencer v. Commonwealth, 240 Va. 78 (deference to trial judge’s observation of juror demeanor in ruling on challenges for cause)
Jackson v. Commonwealth, 267 Va. 178 (trial court’s discretion in evaluating juror responses will not be disturbed absent manifest error)