Felkner v. Jackson
131 S. Ct. 1305
SCOTUS2011Background
- Jackson was convicted in California of multiple sexual offenses arising from an attack on a 72-year-old woman.
- Jackson raised a Batson claim alleging the prosecutor struck black jurors based on race; two of three black jurors were struck, one served on the jury.
- Trial counsel did not object to the first strike (Juror S) at the time, deeming it a 'close call'; later challenged both strikes in a Batson motion.
- The prosecutor offered race-neutral explanations for striking Juror S (harassment by police based on race and age) and Juror J (educational background as a social worker).
- California appellate courts upheld the trial court, applying a substantial-evidence standard and deferring to the trial court on sham vs. bona fide explanations.
- The federal district court denied habeas relief under AEDPA; the Ninth Circuit reversed in a brief memorandum, remanding for further factual discussion, which this Court reverses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether AEDPA deference governs review of Batson credibility findings | Jackson contends state-court findings were unreasonable. | Felkner argues the state court's credibility determinations were permissible and supported by the record. | Defer to state court findings; no unreasonable determination. |
| Whether the state court's comparison of jurors showed pretext or discrimination | Jackson argues comparators show pretext; two out of three black jurors struck implies purposeful discrimination. | Felkner maintains race-neutral explanations were credible and properly applied. | State court reasonably credited race-neutral explanations; no pretext shown. |
| Whether the Ninth Circuit erred in reversing the decision without detailed analysis | Jackson asserts the Ninth Circuit inadequately explained its conclusion. | Felkner contends deference to trial court credibility findings precludes reversal. | Ninth Circuit decision reversed; proper deference upheld. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (prohibits racial discrimination in peremptory jury challenges)
- Snyder v. Louisiana, 552 U.S. 472 (U.S. 2008) (requires careful review of credibility/CV in Batson-like claims)
- People v. Alvarez, 14 Cal.4th 155 (Cal. 1996) (California substantial-evidence standard for appellate review)