Aaron Wilson v. Darrel Vannoy, Warden
708 F. App'x 804
| 5th Cir. | 2017Background
- Appellant Wilson was convicted of first-degree murder; he raised a Batson challenge to the prosecutor’s peremptory strikes of several prospective jurors, chiefly Maxile and Mitchell.
- Prosecutor’s race-neutral reasons: Maxile was a volunteer teacher at the school Wilson attended; Mitchell was married to a minister—reasons tied to presumed views on the death penalty.
- The state trial judge expressed concern about strikes by both sides, noted possible pretext, but ultimately concluded no Batson violation.
- The Louisiana intermediate appellate court reviewed the record, found the prosecutor’s reasons facially race-neutral, and concluded the trial court’s factual handling was flawed but that no Batson violation could be shown.
- Post-state-court review: Wilson exhausted state remedies, Louisiana Supreme Court denied writ, U.S. Supreme Court denied certiorari; on federal habeas the district court denied relief and the Fifth Circuit (applying AEDPA deference) affirmed.
Issues
| Issue | Plaintiff's Argument (Wilson) | Defendant's Argument (State/Prosecutor) | Held |
|---|---|---|---|
| Whether prosecutor’s peremptory strikes were racially motivated (Batson) | Strikes of African-American jurors (esp. Maxile, Mitchell) were pretextual and produced a racially disproportionate result requiring relief | Proffered reasons (teacher at appellant’s school; spouse a minister) were race-neutral and matched how prosecutors struck comparators | Affirmed: under AEDPA, state appellate court reasonably applied Batson; no federal habeas relief |
| Whether trial court’s inconsistent findings required deference to its credibility determinations | Trial court’s oral and written statements showed concern and suggested pretext; plaintiff argued its conclusion was unreliable | State argued appellate court properly examined record and could correct trial-court inconsistencies | Held: Appellate court’s reexamination was reasonable; trial-court handling was flawed but did not render appellate decision unreasonable |
| Whether comparators showed pretext (Miller-El comparators) | Wilson pointed to unstruck similarly-situated white jurors (e.g., church members, coach) to show pretext | State showed differences among comparators (minister vs. lay church members; coach had a relative murdered) undermining comparator equivalence | Held: Appellate court reasonably found comparators were not true matches; proffered reasons not shown pretextual |
| Whether federal habeas relief is barred by AEDPA deference | Wilson argued state-court decision was incorrect on Batson and factual findings | State argued AEDPA requires deference unless decision was unreasonable under clearly established Supreme Court law | Held: AEDPA deference applies; state court decision was not an unreasonable application of clearly established law — habeas relief denied |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (challenge to race-based peremptory strikes)
- Harrington v. Richter, 562 U.S. 86 (AEDPA deference; unreasonable application standard)
- Thaler v. Haynes, 559 U.S. 43 (review limits on habeas relief)
- Miller-El v. Dretke, 545 U.S. 231 (use of comparators in Batson analysis)
- White v. Woodall, 134 S. Ct. 1697 (AEDPA review nuances)
- Montgomery v. Louisiana, 136 S. Ct. 718 (juvenile sentencing/resentencing context)
- Splawn v. Thaler, [citation="494 F. App'x 448"] (5th Cir. treatment of Batson factual determinations)