Gregory James Shelton v. State, 01-15-01056-CR

Gregory James Shelton, an African American, was tried for the murder of Edward Rivera; a jury found him guilty and sentenced him to life imprisonment.
Two psychiatrists (Dr. Axelrad and Dr. Harrison) examined Shelton; reports showed a history of bipolar disorder and prior PTSD but concluded bipolar was in partial remission and no active PTSD at the time of the offense.
After voir dire, the State used a peremptory strike to remove the only remaining African-American venireperson (Juror No. 4); Shelton raised a Batson challenge which the trial court denied.
The prosecutor gave two race-neutral reasons: Juror No. 4 appeared associated with motorcycles ("biker-type wear") and indicated he personally would want to testify if he were a defendant, suggesting potential inability to accept Shelton’s decision not to testify.
Shelton later moved for a new trial alleging ineffective assistance of counsel at punishment because trial counsel (Kenneth Cager) did not present the psychiatric evaluations or medical records as mitigation; counsel testified this was a strategic decision based on his conversations with Shelton and the doctors’ reports.
The court of appeals affirmed: it held the prosecution’s reasons for the peremptory strike were race-neutral and that Shelton failed to prove deficient performance or prejudice on his ineffective-assistance claim.

Issue	Plaintiff's Argument (Shelton)	Defendant's Argument (State)	Held
Denial of Batson challenge to peremptory strike of sole remaining African-American juror	Strike was racially motivated; no legitimate reason for removal	Strike was race-neutral: juror’s biker-style shirt and statements about wanting to testify raised concern about following law and treating silence as evidence	Court upheld denial; prosecutor’s reasons deemed race-neutral and not clearly erroneous
Ineffective assistance at punishment for not presenting psychiatric evidence	Counsel unreasonably failed to introduce mental-health records and evaluations as mitigating evidence	Counsel made a reasonable strategic decision; records showed disorders were in partial remission and not active at offense	Court rejected claim: performance not shown deficient and no prejudice demonstrated

Batson v. Kentucky, 476 U.S. 79 (prohibition on race-based peremptory strikes)
Purkett v. Elem, 514 U.S. 765 (Batson three-step framework)
Miller-El v. Dretke, 545 U.S. 231 (burden to provide clear, reasonably specific race-neutral reasons)
Gibson v. State, 144 S.W.3d 530 (appellate review standard for Batson rulings)
Strickland v. Washington, 466 U.S. 668 (two-prong ineffective-assistance standard)
Lopez v. State, 343 S.W.3d 137 (difficulty of proving ineffectiveness on direct appeal)