David Minor v. Beverly Hastings, 704 F. App'x 103

David Minor was convicted in New Jersey and raised two federal habeas claims after state appeals: (1) the prosecutor’s summation misstated the burden of proof and effectively directed a guilty verdict, and (2) the trial court failed to find a prima facie Batson violation in jury selection.
The New Jersey Appellate Division rejected both claims; the New Jersey Supreme Court denied review. Minor then filed a pro se §2254 habeas petition, which the District Court denied.
This Court granted a Certificate of Appealability limited to the two issues: the prosecutor’s summation (Darden claim) and the Batson/Jonson step-one inquiry.
Under AEDPA, the federal court may grant relief only if the state court’s decision was contrary to, or an unreasonable application of, clearly established federal law, or an unreasonable determination of the facts.
The panel reviewed (deferentially) whether the state courts unreasonably applied Darden and Johnson/Batson and affirmed the District Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prosecutor's summation violated due process by misstating "beyond a reasonable doubt" and directing verdict	Minor: summation so prejudicial, especially given weak evidence, that conviction denied due process	State: comments were responsive to defense, did not misstate evidence; trial judge gave curative instructions including correct burden	Court: No due process violation under AEDPA; comments remedied by curative instruction and were invited/reply to defense
Batson prima facie showing / Johnson step-one error	Minor: trial court unreasonably required too much at step one and failed to infer discrimination from pattern/questions	State: prosecutor offered race-neutral reasons; trial court credited them; ultimate jury composition and credited explanations undercut Batson claim	Court: Although record is troubling, trial court’s credibility findings and race-neutral explanations were not an unreasonable determination of facts under AEDPA; affirmed

Darden v. Wainwright, 477 U.S. 168 (1986) (prosecutorial misconduct standard for due process review)
Batson v. Kentucky, 476 U.S. 79 (1986) (framework for challenging peremptory strikes as racial discrimination)
Johnson v. California, 545 U.S. 162 (2005) (clarified burden at Batson step one; defendant need not prove purposeful discrimination at step one)
Williams v. Taylor, 529 U.S. 362 (2000) (AEDPA’s deferential standard for federal habeas review)
Miller-El v. Cockrell, 537 U.S. 322 (2003) (deference to trial-court credibility findings on discriminatory intent at Batson step three)