579 U.S. 913
SCOTUS2016Background
- Curtis Giovanni Flowers petitioned the Supreme Court after the Mississippi Supreme Court upheld the trial judge's Batson ruling rejecting claims that prosecutors struck jurors based on race.
- The Supreme Court GVR'd (grant, vacate, remand) Flowers's petition in light of this Court's decision in Foster v. Chatman, and remanded to the Mississippi Supreme Court for further consideration.
- Justice Alito, joined by Justice Thomas, dissented from the GVR, arguing the GVR procedure was misused here.
- The dissent contends Foster did not change or clarify Batson; Foster was a fact-specific Batson decision based on extensive case-specific evidence of racial bias in the prosecution's files and inconsistent justifications for strikes.
- Alito argued that because the Mississippi Supreme Court already adjudicated the Batson factual finding and afforded deference to the trial judge, the proper course was either full grant of certiorari for this Court to review or denial of the petition, not a GVR.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court should GVR in light of Foster v. Chatman | Flowers: Foster warrants reconsideration of Batson findings by the state court | State/Mississippi: Foster did not change Batson; state court correctly applied Batson deference | Majority: GVR and remand to state court for reconsideration in light of Foster |
| Whether Foster altered Batson's legal standard | Flowers: Foster supplies governing guidance applicable to similar claims | State: Foster was fact-specific and did not change Batson law | Dissent: Foster did not change Batson; it applied Batson to unique facts |
| Proper use of GVR when lower court made factual Batson findings | Flowers: Remand appropriate to reassess factual findings under Foster | State: Lower court already resolved facts; GVR is inappropriate passive review | Dissent: GVR misapplied; should grant cert or deny petition rather than remand |
| Deference to trial judge's credibility findings under Batson | Flowers: Lower court should reassess credibility in light of new precedent/facts | State: Trial-court credibility determinations merit strong deference; no basis to overturn | Dissent: Emphasizes deference; remanding without pointing to error improperly orders redo of work |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (establishing three-step Batson framework for peremptory strikes)
- Snyder v. Louisiana, 552 U.S. 472 (trial judge credibility findings on Batson entitled to deference)
- Foster v. Chatman, 578 U.S. _ (2016) (Court found extensive case-specific evidence showing race-based strikes and unreliable prosecutorial explanations)