Haney v. Adams
2011 U.S. App. LEXIS 10571
9th Cir.2011Background
- Monte L. Haney, an African American, was convicted in California in 2005 of aggravated mayhem, torture, assault with force likely to produce great bodily injury, assault with a deadly weapon, corporal injury on a cohabitant, and criminal threats.
- During voir dire, the prosecutor used peremptory challenges to strike nine potential jurors; Haney did not object to these challenges at trial.
- The resulting jury included Asian, white, and Hispanic members, but no African Americans.
- Haney appealed to the California Court of Appeal in 2006; the convictions were affirmed and no Batson claim was raised on direct appeal.
- The California Supreme Court denied review; in 2007 Haney filed state habeas with claims including Batson; it was denied without opinion.
- Haney then filed federal habeas in the Northern District of California; the district court denied the petition, including the Batson claim, on both procedural and merits grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Contemporaneous objection requirement for Batson on habeas | Haney contends Batson may be raised despite no trial objection. | Adams argues lack of trial objection forecloses Batson claim in habeas. | Timely contemporaneous objection required; no Batson claim in habeas. |
| Standard of review for state court decisions under AEDPA | Haney argues the state court decision was unreasonable under Batson. | Respondent argues de novo review with AEDPA constraints applies; no unreasonable application found. | We conduct independent review when no reasoned state court decision exists; state decision not unreasonable. |
| Batson procedure and its reliance on trial-record observations | Haney asserts Batson framework applies; record supports discrimination. | Respondent maintains lack of trial objection prevents meaningful Batson inquiry in habeas. | Contemporaneous objection prerequisite; three-step Batson framework requires timely objection. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (1986) (Equal Protection prohibits race-based peremptory challenges; outlines Batson framework)
- Ford v. Georgia, 498 U.S. 411 (1991) (states may set timeliness rules for Batson objections)
- Snyder v. Louisiana, 552 U.S. 472 (2008) (demeanor and first-hand observations heighten importance of trial-record credibility)
- McCrory v. Henderson, 82 F.3d 1243 (2d Cir. 1996) (post-conviction Batson relief requires record; difficulty after long delays)
- Abu-Jamal v. Horn, 520 F.3d 272 (3d Cir. 2008) (reliance on contemporaneous objections in evaluating Batson claims)
- Jones v. Butler, 864 F.2d 348 (5th Cir. 1988) (post-conviction Batson review requires preserved record; timing matters)
- Galarza v. Keane, 252 F.3d 630 (2d Cir. 2001) (record preservation impacts Batson review over long delays)
- Pinholster v. Cullen, 131 S. Ct. 1388 (2011) (AEDPA review scope and independent review considerations)