Averill Briggs v. Randy Grounds
2012 U.S. App. LEXIS 12167
| 9th Cir. | 2012Background
- Briggs challenged his conviction, arguing the prosecutor used peremptory challenges to strike three African American jurors in a cross-racial case.
- Jury pool from Alameda County consisted of 65; the prosecutor used 18 of 20 peremptory challenges, striking three AA jurors (Lawrence L., Georgia M., Sam R.).
- Trial court held the strikes for race-neutral reasons; Briggs moved for new trial and appellate review upheld the race-neutral justifications; California Supreme Court denied review.
- Briggs filed a federal habeas petition; district court concluded no Batson violation after reviewing the comparative analysis and voir dire.
- The Ninth Circuit applied AEDPA deferential review to determine whether state court decisions were objectively unreasonable in crediting the prosecutor’s race-neutral explanations.
- The core issue is whether Briggs suffered a Batson violation at step three, given the three AA jurors struck and the comparative analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the state court reasonably applied Batson at step three under AEDPA. | Briggs: state court misapplied Batson and relied on pretextual justifications. | Wheeler/Batson framework satisfied; credibility deference afforded to trial court findings under AEDPA. | No, state court reasonably applied Batson; no disparate intent found. |
| Whether the comparative juror analysis was properly conducted for Batson review. | Briggs: appellate court ignored numerous pretextual rationales and relied on one non-pretextual reason. | California appellate court reasonably assessed comparative analysis and credited substantive race-neutral justifications. | Yes, the comparison supported the non-pretextual conclusions; not objectively unreasonable. |
| Whether the individual race-based challenges to Jurors Lawrence L., Georgia M., and Sam R. were race-neutral. | Briggs: multiple pretextual reasons show impermissible discrimination against AA jurors. | Prosecutor’s justifications, viewed holistically, were credible and not pretextual. | Yes, the challenges were race-neutral under the record; no Batson violation found. |
| Whether cumulative Batson analysis supports reversal given three AA jurors were struck. | Briggs: the pattern shows purposeful discrimination even if some reasons appear neutral. | Consistency of questioning and race-neutral rationales across jurors undermines an inference of discrimination. | No, the cumulative record does not establish a Batson violation under AEDPA. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (peremptory challenges disallowed for purposeful racial discrimination)
- Miller-El v. Dretke, 545 U.S. 231 (U.S. 2005) (comparative juror analysis; race-neutral explanations must be evaluated collectively)
- Kesser v. Cambra, 465 F.3d 351 (9th Cir. 2006) (en banc; importance of thorough Batson step-three analysis)
- Rice v. Collins, 546 U.S. 333 (U.S. 2006) (highly deferential AEDPA standard; credibility of prosecutor's explanations)
- Snyder v. Louisiana, 552 U.S. 472 (U.S. 2008) (demeanor-based reasons and comparative analysis under Batson)
- Ali v. Hickman, 584 F.3d 1174 (9th Cir. 2009) (pretextual explanations support inference of discriminatory intent)
- Ngo v. Giurbino, 651 F.3d 1112 (9th Cir. 2011) (comparator evidence reinforcing race-neutral justification sufficiency)
- Cook v. LaMarque, 593 F.3d 810 (9th Cir. 2010) (deference to state court credibility findings; Batson step-three review)
- United States v. Horsley, 864 F.2d 1543 (11th Cir. 1989) (rapport-based justification; limitations of subjective reasoning)