In the Turner v. Murray case of 1985, the U.S. Supreme Court ruled that a black defendant facing capital punishment has a constitutional right to have prospective jurors informed about his race and questioned on whether they harbor racial bias. The petitioner, Willie Lloyd Turner, was sentenced to death by an all-white jury for murdering a white store owner during an armed robbery in Virginia. He appealed his sentence arguing that he was denied equal protection under the Fourteenth Amendment because potential jurors were not asked about possible racial prejudice during voir dire (preliminary examination). The court held in a 5-4 decision that when defendants are able to demonstrate their cases' "special circumstances" - such as being charged with interracial capital crimes - they should be allowed to question potential jurors regarding racial bias.

In the dissenting opinion for Turner v. Murray, Justice White argued that it was not constitutionally required to question prospective jurors about racial bias in every case where a black defendant is charged with a violent crime against a white victim. He contended that such an approach could lead to unnecessary and potentially harmful implications of racism in cases where race may not be relevant at all. Furthermore, he expressed concern over the majority's assumption that potential racial prejudice would only affect white jurors' decisions regarding black defendants, arguing this presumption itself was racially biased. He also pointed out inconsistencies between this ruling and previous court rulings which did not require questioning on other types of potential biases (such as gender or religion). Ultimately, Justice White believed the decision should have been left up to trial judges who are best positioned to determine if there is substantial indication of racial bias among jury members.