Akins v. Easterling
648 F.3d 380
6th Cir.2011Background
- Akins was convicted in Williamson County, Tennessee in 1998 of one count of especially aggravated robbery for a carjacking.
- He was initially charged in a juvenile petition but ultimately tried as an adult, with appointed counsel and a request to represent himself granted, allowing elbow counsel.
- At sentencing, Akins was deemed a violent offender and sentenced to 20 years; the jury fined $50,000, later reduced to $1,000 by the trial judge.
- The Tennessee Court of Criminal Appeals affirmed Direct Review, and the Tennessee Supreme Court denied permission to appeal; Akins later sought post-conviction relief which was denied.
- Akins filed a pro se habeas petition in 2007 raising four grounds; the district court dismissed on merits, and the Sixth Circuit granted a certificate on Batson and self-representation issues.
- The Sixth Circuit affirmed the district court, reviewing under AEDPA standards on the merits of the Batson and self-representation claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Batson step two race-neutral explanations | Akins argues prosecutor's third proffered reason tainted step two. | Easterling contends reasons were race-neutral and supported | Not contrary; reasons race-neutral under Batson |
| Batson step three discriminatory intent | Akins contends sole-motivation standard is unconstitutional; mixed-motive or per se analysis required. | State court applied sole-motivation standard; not unreasonable | Not unreasonable application; state court's sole-motivation standard not clearly unreasonable |
| Self-representation waiver knowing and voluntary | Waiver was not knowing, voluntary, or intelligent due to inadequate inquiry | Waiver was knowing and voluntary; judge conducted substantial questioning | Not contrary; waiver deemed knowing and voluntary |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (prohibits peremptory challenges based solely on race)
- Hernandez v. New York, 500 U.S. 352 (U.S. Supreme Court) (race-neutral explanations sufficient at Batson step two)
- Snyder v. Louisiana, 552 U.S. 472 (U.S. 2008) (discusses discriminatory intent in Batson context; not clearly established law at time here)
- Von Moltke v. Gillies, 332 U.S. 708 (U.S. 1948) (waiver to be valid must be informed and voluntary)
- Purkett v. Elem, 514 U.S. 765 (U.S. 1995) (neutral explanations need not be persuasive; not inherently discriminatory)
- Martinez-Salazar, 528 U.S. 304 (U.S. 2000) (prohibition on peremptory strikes based solely on race)
- Tovar v. Iowa, 541 U.S. 77 (U.S. 2004) (waiver of counsel inquiry contextual factors; not a rigid checklist)
- Dretke v. Cockrell, 545 U.S. 231 (U.S. 2005) (AEDPA standard for unreasonable determinations of fact)
- Faretta v. California, 422 U.S. 806 (U.S. 1975) (right to self-representation; trial court must ensure knowing waiver)