Batson Challenge and Jury Selection: Sufficiency Of The Race Neutral Explanation By The Prosecution
FELKNER V. JACKSON
United States Supreme Court
Decided March 21, 2011
Issue: Whether the prosecutor had given a sufficiently race neutral reason to the Batson challenge by defense counsel during jury selection.
Holding: The Batson issue turns largely on an evaluation of credibility and the trial court’s determination is entitled to great deference and must be sustained unless it is clearly erroneous. The Supreme Court upheld the trial court’s finding that there was a sufficiently race neutral reason given by the prosecutor for the exclusion of certain jurors.
Facts: A California jury convicted respondent Steven Frank Jackson of numerous sexual offenses stemming from his attack on a 72-year-old woman who lived in his apartment complex. Jackson raised a Batson claim, asserting that the prosecutor exercised peremptory challenges to exclude black prospective jurors on the basis of their race. Jackson’s counsel did not object when the prosecutor struck the first of the black jurors, Juror S. Counsel later explained that he did not make a "motion at that time” because he thought the excusal of Juror S "was a close call.”
After the prosecutor sought to dismiss the second juror, Juror J, Jackson’s counsel made the Batson motion challenging both strikes. The prosecutor offered a race-neutral explanation for striking each juror: Juror S had stated that from the ages of 16 to 30 years old, he was frequently stopped by California police officers because-in his view-of his race and age. As the prosecutor put it, "Whether or not he still harbors any animosity is not something I wanted to roll the dice with. The prosecutor stated that he struck Juror J because she had a master’s degree in social work, and had interned at the county jail, "probably in the psych unit as a sociologist of some sort.”
The prosecutor explained that he dismissed her "based on her educational background,” stating that he does not "like to keep social workers. Jackson’s counsel expressly disagreed only with the prosecutor’s explanation for the strike of Juror J, see App. to Pet. for Cert. 22–23, 47, arguing that removing her on the basis of her educational background was "itself invidious discrimination.” The prosecutor responded that he was not aware that social workers were a "protected class.” As for Juror S, Jackson’s counsel explained that he "let [Juror S] slide” because he anticipated the prosecutor’s response and, in any event, he "only need[ed] one to establish the grounds for” a Batson motion. After listening to each side’s arguments, the trial court denied Jackson’s motion.
After the California Supreme Court denied Jackson’s petition for review, Jackson sought federal habeas relief. The Federal District Court properly recognized that review of Jackson’s claim was governed by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). That law provides, in pertinent part, that federal habeas 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 pre- sented in the State court proceeding.” 28 U. S. C. §2254(d)(2). After considering the state Court of Appeal decision and reviewing the record evidence, the District Court held that the California Court of Appeal’s findings were not unreasonable.
Legal Analysis : The Batson issue before us turns largely on an "evaluation of credibility.” 476 U. S., at 98, n. 21. The trial court’s determination is entitled to "great deference,” and "must be sustained unless it is clearly erroneous,” Snyder v. Louisiana, 552 U. S. 472, 477 (2008).
That is the standard on direct review. On federal habeas review, AEDPA "imposes a highly deferential standard for evaluating state-court rulings” and "demands that state-court decisions be given the benefit of the doubt.” Renico v. Lett, 559 U. S. ___, ___ (2010) (slip op., at 5). The state appellate court’s decision was plainly not unreasonable. There was simply no basis for the Ninth Circuit to reach the opposite conclusion, particularly in such a dismissive manner.
The petition for certiorari and the motion for leave to proceed in forma pauperis are granted. The judgment of the Court of Appeals for the Ninth Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion.