Kevin Maddox v. M. Spearman
20-55024
| 9th Cir. | Jul 19, 2021Background
- Petitioner Kevin Maddox appealed the denial of his 28 U.S.C. § 2254 habeas petition after the district court rejected his Batson challenge to the prosecutor’s peremptory strikes.
- The district court found Maddox established a prima facie Batson showing and that the prosecutor offered race-neutral reasons for the strikes, but concluded Maddox failed to prove purposeful discrimination at Batson step three.
- The state court allegedly applied a heightened step-one standard — requiring a “strong likelihood” of discrimination rather than a “reasonable inference” — so AEDPA deference was held inapplicable on federal review.
- Maddox relied on comparative juror analysis (comparing struck Black veniremembers to seated jurors) to show pretext; the trial record before the federal courts did not identify the race of all venire or seated jurors, and the district court acknowledged the record gaps.
- Maddox requested an evidentiary hearing and additional state-court records to determine juror races for the step-three analysis; the district court denied those requests and dismissed the petition.
- The Ninth Circuit vacated and remanded, instructing the district court to obtain the missing state-court record and hold an evidentiary hearing so it can consider all relevant circumstances (including comparative juror analysis).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the state court applied an incorrect Batson step-one standard, affecting AEDPA deference | Maddox: state court used “strong likelihood” standard instead of “reasonable inference,” so AEDPA deference does not apply | State: (implicit) apply deference to state-court ruling | Court: Agreed state court applied wrong standard; AEDPA deference does not apply |
| Whether Maddox proved purposeful racial discrimination at Batson step three | Maddox: comparative juror evidence shows prosecutor’s race-neutral reasons were pretextual | State: prosecutor offered race-neutral reasons; district court found no purposeful discrimination | Court: Step-three review cannot be completed on current record; relief not decided — remand for further factfinding |
| Whether the district court erred by denying an evidentiary hearing and failing to obtain missing state-court record | Maddox: hearing and fuller record required for comparative analysis and step-three Batson inquiry | State: (implicit) existing record sufficient; no hearing required | Court: District court erred; vacated and remanded for evidentiary hearing and collection of relevant state-court record |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (1986) (establishes three-step framework for evaluating peremptory strikes)
- Miller-El v. Dretke, 545 U.S. 231 (2005) (side-by-side comparative juror analysis can show pretext)
- Flowers v. Mississippi, 139 S. Ct. 2228 (2019) (comparisons of struck and seated jurors inform Batson inquiry)
- Johnson v. Finn, 665 F.3d 1063 (9th Cir. 2011) (AEDPA deference and Batson standards)
- Hurles v. Ryan, 752 F.3d 768 (9th Cir. 2014) (standard of review for § 2254 denials)
- Shirley v. Yates, 807 F.3d 1090 (9th Cir. 2015) (three-step Batson burden-shifting summary)
- Boyd v. Newland, 467 F.3d 1139 (9th Cir. 2006) (comparative juror analysis is a Batson centerpiece)
- Jamerson v. Runnels, 713 F.3d 1218 (9th Cir. 2013) (importance of knowing venire members’ race for Batson review)
- Nasby v. McDaniel, 853 F.3d 1049 (9th Cir. 2017) (remand when district court fails to obtain relevant state-record evidence)