By Darren Chaker
On federal habeas review, the United States Supreme Court decided Felkner v. Jackson, Case #: 10-797 [3/21/2011]. AEDPA imposes a highly deferential standard for evaluating state court rulings, including a denial of a Batson claim. Jackson was convicted in the state court of numerous sexual offenses.
At trial, counsel objected to the prosecution's dismissal of two jurors, claiming the prosecution exercised its peremptory challenges to exclude prospective black jurors on the basis of race. After the prosecution offered race-neutral explanations, the trial court denied Jackson's Batson motion. The appellate court found no error and the California Supreme Court denied review. Jackson then sought federal habeas relief but the federal district court denied the petition, finding that the California rulings were not unreasonable.
The Ninth Circuit Court of Appeals reversed in a one-sentence conclusory explanation. The US Supreme Court found the decision of the Ninth Circuit to be inexplicable and reversed. In this case, the record indicated that the trial court credited the prosecutor's race-neutral explanation and the appellate court carefully reviewed the record in upholding the trial court's finding. Thus, the state appellate court's decision was clearly not unreasonable and there was no basis for the Ninth Circuit's conclusion.