723 F.3d 976
9th Cir.2013Background
- Aleman and Maldonado were tried jointly in Los Angeles County for attempted first‑degree murder of a peace officer and robbery, with gang enhancements.
- During voir dire, the prosecutor used four of his first five peremptory challenges to strike Hispanic jurors.
- Defense raised a Batson challenge alleging racial discrimination; the trial court found a prima facie case and asked for race‑neutral explanations.
- The prosecutor excused Juror Acevedo based on a belief she was too 'prissy' for police work; similar reasons were given for other Hispanic jurors.
- The trial court and California Court of Appeal upheld the Batson ruling, finding the explanations credible and not pretextual.
- On § 2254 review, the district court and this court apply AEDPA’s deferential standard and uphold the state courts’ credibility determinations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Batson ruling was properly upheld. | Aleman contends the prosecutor’s race‑neutral explanations were pretextual. | Uribe contends the court should scrutinize the reasons and not accept honesty as a defense against discrimination. | Not an unreasonable application; honest mistake findings upheld. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (prohibits racial discrimination in peremptory strikes)
- Miller‑El v. Dretke, 545 U.S. 231 (U.S. 2005) (prosecutor’s mischaracterization can signal discrimination)
- Rice v. Collins, 546 U.S. 333 (U.S. 2006) (honest mistakes in explanations reviewed for credibility)
- Purkett v. Elem, 514 U.S. 765 (U.S. 1995) (credible explanations need not be perfect; focus on persuasiveness)
- Kesser v. Cambra, 465 F.3d 351 (9th Cir. 2006) (evaluates persuasiveness of race‑neutral justifications)
- Crittenden v. Ayers, 624 F.3d 943 (9th Cir. 2010) (AEDPA review and factual determinations apply to Batson claims)
- Jamerson v. Runnels, 713 F.3d 1218 (9th Cir. 2013) (requires deference to trial court credibility findings)
- Burks v. Borg, 27 F.3d 1424 (9th Cir. 1994) (consideration of minority juror acceptance in Batson context)
- Wheeler v. Superior Court, 583 P.2d 748 (Cal. 1978) (California analog to Batson (People v. Wheeler))
- Slack v. McDaniel, 529 U.S. 473 (U.S. 2000) (AEDPA deference standard for habeas review)