Headline: Avoiding race specific and discriminatory language may help prosecutors survive a Batson motion, even when a prosecutor had a clear agenda to strike prospective black jurors from the jury.
Area of Law: Criminal Procedure, Habeas Corpus, Jury Selection Process
Issue Presented: Whether the California Court of Appeal was objectively unreasonable under “the doubly deferential standard” applied to collateral review of the Batson motions under the Antiterrorism and Effective Death Penalty Act (AEPDA) in affirming the trial court’s determination that the prosecutor’s reasons for striking the individual jurors were nondiscriminatory and whether the trial court’s denial of defendant’s request for rebuttal on the first two Batson motions in which five black jurors were excluded constituted an error that resulted in “actual prejudice” towards Sifuentes.
Brief Summary: Defendant Miguel Galindo Sifuentes was convicted of first degree murder. He made three objections during jury selection under Batson v. Kentucky, 476 U.S. 79 (1986). The trial court requested the prosecutor to explain the reasons for excusing the nine black prospective jurors. It determined that the reasons were race neutral and not discriminatory and denied the Sifuentes’s request for rebuttal for the first two Batson motions, but granted the third. The California Court of Appeal affirmed the trial court’s decision despite recognizing its error in denial of defendant’s rebuttal on the motions. The California Supreme Court denied defendant’s petition for review. Sifuentes then petitioned for a writ of habeas corpus in federal court. This request was partially granted by the district court. The United States Court of Appeals for the Ninth Circuit reversed the district court’s grant of a writ of habeas corpus because after applying the AEDPA, 28 U.S.C. § 2254, doubly deferential standard to the Batson challenges on collateral review the panel found that the state appellate court’s holding was not objectively unreasonable in upholding the trial court’s determination.