Amos Jackson v. Pat Horn, 21-55849

Petitioner Amos Jackson appealed the district court’s denial of his federal habeas petition challenging a California state conviction.
Jackson argued the prosecutor violated Batson by using a peremptory strike on the only African‑American veniremember (Juror 42) when Jackson and his codefendants are African‑American.
The trial court ruled Jackson failed to make a prima facie Batson showing; it did not adjudicate the prosecutor’s proffered race‑neutral reasons.
The prosecutor had voluntarily offered that Juror 42 avoided eye contact with the prosecutor during voir dire and stared at the defendants.
Under AEDPA review, the Ninth Circuit treated the state appellate decision as the relevant state‑court ruling and reviewed for whether that decision was contrary to or an unreasonable application of clearly established federal law.
The Ninth Circuit affirmed: striking the sole African‑American on a 69‑person venire does not alone establish discriminatory intent, and Jackson failed to show pretext under Batson.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether excusing the only African‑American veniremember creates a prima facie Batson showing	Jackson: excusing the only African‑American juror (when defendants are African‑American) supports an inference of discrimination	State: striking a single Black juror from a large venire does not establish a pattern or trend indicating discrimination	Held: No prima facie showing; a single strike on a 69‑person venire is insufficient (Collins principle)
Whether the prosecutor’s offered reasons were pretextual	Jackson: prosecutor’s reasons (eye contact/staring) were pretext for racial discrimination	State: prosecutor offered race‑neutral explanations; trial court did not reach credibility because no prima facie showing was made	Held: Court did not need to reach Batson steps 2–3; even if considered, Jackson failed to show pretext or an unreasonable factual determination
Whether AEDPA permits federal habeas relief on this Batson claim	Jackson: state court unreasonably applied Batson and related precedent	State: state appellate decision was reasonable under clearly established law and factbound	Held: Under AEDPA, Jackson did not show the state court’s decision was contrary to or an unreasonable application of Supreme Court Batson precedent

Batson v. Kentucky, 476 U.S. 79 (1986) (establishes three‑step framework for challenging race‑based peremptory strikes)
United States v. Collins, 551 F.3d 914 (9th Cir. 2009) (striking the sole juror of a racial group on a large venire does not by itself establish discriminatory intent)
People v. Crittenden, 885 P.2d 887 (Cal. 1994) (use of peremptories to excuse all members of a group supports an inference of discrimination in some contexts)
United States v. Mikhel, 889 F.3d 1003 (9th Cir. 2018) (discusses Batson three‑step review and clear‑error standard on credibility findings)
United States v. Alvarez‑Ulloa, 784 F.3d 558 (9th Cir. 2015) (Batson framework citation)
Snyder v. Louisiana, 552 U.S. 472 (2008) (credibility determinations in Batson step three are given deference)
Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA standard for federal habeas relief)
Berghuis v. Thompkins, 560 U.S. 370 (2010) (treats last reasoned state‑court decision as the relevant decision under AEDPA)
United States v. Guerrero, 595 F.3d 1059 (9th Cir. 2010) (if no prima facie showing, courts need not reach later Batson steps)
Murray v. Schriro, 745 F.3d 984 (9th Cir. 2014) (describes AEDPA "look‑through" to the last reasoned state decision)