Challenges to jury race-makeup tightened

March 21, 2011 at 12:54 PM
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WASHINGTON, March 21 (UPI) -- The U.S. Supreme Court ruled unanimously Monday that federal courts have to have a good reason to reverse state court rulings on juries and race.

The ruling came in a "per curiam," or unsigned, opinion, that is particularly critical of the U.S. Court of Appeals for the 9th Circuit.

A California jury convicted Steven Frank Jackson of "numerous sexual offenses stemming from his attack on a 72-year-old woman who lived in his apartment complex," the high court opinion said. But Jackson's attorney claimed the prosecutor exercised peremptory challenges to exclude black prospective jurors on the basis of their race.

Such challenges are called "Batson claims," based on the Supreme Court's 1986 ruling in Batson vs. Kentucky.

Two of three black potential jurors had been struck from the panel before Jackson's trial; a third served on the jury.

The trial judge denied Jackson's Batson claim. After a state appeals court upheld the denial after Jackson's conviction, he asked for federal review.

A federal judge also denied the claim, citing the 1996 Anti-terrorism and Effective Death Penalty Act, which says federal "relief may not be granted unless the state court adjudication 'resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the state court proceeding.'"

But the 9th Circuit reversed. "In so doing, the (appeals) court did not discuss any specific facts or mention the reasoning of the other three courts that had rejected Jackson's claim," the Supreme Court opinion said. The 9th Circuit ruling said, "The prosecutor's proffered race-neutral bases for peremptorily striking the two African-American jurors were not sufficient to counter the evidence of purposeful discrimination in light of the fact that two out of three prospective African-American jurors were stricken, and the record reflected different treatment of comparably situated jurors."

"That decision is as inexplicable as it is unexplained," the Supreme Court said. "It is reversed."

"AEDPA 'imposes a highly deferential standard for evaluating state-court rulings' and 'demands that state-court decisions be given the benefit of the doubt," the Supreme Court said, citing a 2010 precedent.

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