Joel Munt v. Kent Grandlienard, 829 F.3d 610

Joel Munt was convicted in Minnesota state court of murdering his ex-wife and kidnapping their three children; he raised a not-guilty-by-reason-of-mental-illness defense at trial.
During voir dire, juror B.S. said she would presume Munt innocent and could follow the court's legal instructions; defense did not strike her then with a peremptory challenge or cause.
On cross-examining B.S., the prosecutor asked her general view of a defendant who confesses but claims mental illness; B.S. replied that a confession makes someone aware and responsible despite mental illness.
Defense later sought to challenge B.S. for cause after the prosecutor's exchange; the trial court denied reopening voir dire and seated B.S.
Munt appealed and then sought federal habeas relief, arguing B.S. was actually biased against the mental-illness defense and that Minnesota courts unreasonably applied Supreme Court precedent (Morgan).
The district court denied habeas relief; the Eighth Circuit affirmed, holding the state courts’ factual and legal determinations were reasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juror B.S. expressed actual bias against Munt's mental-illness defense	B.S. made an unequivocal statement that a confession means responsibility despite mental illness, showing actual bias	B.S. merely gave a personal opinion without knowing the law and repeatedly assured she would follow instructions and be impartial	No actual bias; state court's credibility finding was reasonable and not rebutted by clear and convincing evidence
Whether Minnesota courts unreasonably applied Morgan v. Illinois in refusing to remove B.S.	Morgan requires probing juror views that would preclude applying the law to mental-illness defenses; state court should have removed B.S.	Morgan concerns capital-case safeguards and ability to inquire for cause; here defense had opportunity to question and did not pursue further; Morgan not controlling	State court did not unreasonably apply Morgan; the case is distinguishable and procedural protections were satisfied

Morgan v. Illinois, 504 U.S. 719 (1992) (defendant entitled to inquiry to uncover jurors who would pre-determine critical issues)
Irvin v. Dowd, 366 U.S. 717 (1961) (constitutional right to an impartial jury)
Williams v. Taylor, 529 U.S. 362 (2000) (standards for "contrary to" and "unreasonable application" under 28 U.S.C. § 2254(d))
Schriro v. Landrigan, 550 U.S. 465 (2007) (presumption of correctness for state-court factual findings in habeas proceedings)
Skilling v. United States, 561 U.S. 358 (2010) (deference to trial-court determinations of juror bias)
Wainwright v. Witt, 469 U.S. 412 (1985) (juror-bias determinations rely on trial judge's credibility assessments)
Bobadilla v. Carlson, 575 F.3d 785 (8th Cir. 2009) (standard of review for habeas legal conclusions and factual findings)
Williams v. Norris, 612 F.3d 941 (8th Cir. 2010) (definition of "actual bias" requiring an unequivocal, impermissible affirmative statement)