Phillips (defendant) was convicted of murder in the state courts of New York. After being convicted, Phillips learned that one of the jurors had applied during the trial for a job as an investigator with the District Attorney’s office. Phillips appealed his conviction on the ground that the juror was impermissibly biased. Phillips’ conviction was upheld through the state courts. Phillips petitioned the federal district court for a writ of habeas corpus. The district court did not find sufficient evidence to conclude that the juror had actually been biased, but the court imputed bias and reversed Phillips' conviction pending a new trial. The court of appeals affirmed the district court’s decision. The District Attorney’s office petitioned the United States Supreme Court for review.