Porter v. Coyne-Fague, 35 F.4th 68

Background

Petitioner Leron Porter, an African-American, was convicted of second-degree murder and firearms offenses after a 2013 trial in Providence County; jury had no black members because the only black venireperson (Juror 103) was struck peremptorily.
Juror 103 privately told the court he feared "blow-back" or workplace retaliation from patients/staff at the state hospital where he worked if his service and a guilty verdict became known, but he expressly said he could be fair and impartial.
The prosecutor exercised a peremptory strike and explained—unprompted—that he believed Juror 103, as the sole African-American on the panel and sharing race with the defendant, might face consequences for voting guilty and thus be biased against a guilty verdict.
The trial justice accepted a race-neutral justification (focusing on Juror 103's stated fear of retaliation) and excused the juror; the Rhode Island Supreme Court affirmed that the strike was race-neutral.
On federal habeas review the district court found a Batson problem but denied relief under AEDPA deference to the state court; the First Circuit reversed, holding the state court unreasonably applied Batson or unreasonably determined the facts.
The First Circuit ordered the district court to grant the writ, vacate Porter's convictions, and either allow retrial within 90 days or release him.

Issues

Issue	Petitioner's Argument	Respondent's Argument	Held
Whether the prosecutor's peremptory strike of Juror 103 violated Batson (step two: race-neutral explanation)	Prosecutor's explanation expressly relied on shared race as the reason to infer juror bias; that is not race-neutral under Batson	Prosecutor actually relied on juror's expressed fear of retaliation (race-neutral); the racial reference was a descriptive aside	First Circuit: strike was race-based; state court unreasonably applied Batson or misread the facts; explanation was not race-neutral
Whether the Rhode Island Supreme Court's decision is entitled to AEDPA deference under 28 U.S.C. §2254(d)	State court unreasonably applied clearly established Batson precedent and ignored prosecutor's race-explicit rationale	State court reached a permissible, reasonable interpretation of the record; federal court must defer	First Circuit: state decision was an unreasonable application or an unreasonable factual determination under §2254(d)(1)/(d)(2); deference denied
Whether petitioner proved purposeful discrimination (ultimate Batson inquiry) and is entitled to relief (remedy)	The prosecutor's race-explicit reasoning, combined with juror being sole black panelist, shows discriminatory intent; relief requires vacatur and retrial or release	Even if flawed, any error is subject to AEDPA deference; no entitlement to habeas relief	Held: petitioner met burden of purposeful discrimination; Batson violation; grant habeas writ, vacate convictions, retrial within 90 days or release

Key Cases Cited

Batson v. Kentucky, 476 U.S. 79 (1986) (establishes three-step framework for evaluating peremptory strikes under Equal Protection)
Miller-El v. Dretke, 545 U.S. 231 (2005) (post-hoc substitution of reasons cannot cure prosecutor's failure to state a racially neutral explanation)
Flowers v. Mississippi, 139 S. Ct. 2228 (2019) (forbids striking even a single juror for discriminatory purpose; frames ultimate inquiry into discriminatory intent)
Davis v. Ayala, 576 U.S. 257 (2015) (state court interpretations of prosecutor's stated reasons can present factual-determination issues under §2254(d)(2))
Purkett v. Elem, 514 U.S. 765 (1995) (race-neutral explanation requirement at Batson step two; facial neutrality is the threshold)
White v. Woodall, 572 U.S. 415 (2014) (AEDPA requires objectively unreasonable application of Supreme Court holdings)
Williams v. Taylor, 529 U.S. 362 (2000) (defines §2254(d)(1) "contrary to" and "unreasonable application" standards)
Foster v. Chatman, 578 U.S. 488 (2016) (examines discriminatory intent and the impermissibility of using race as proxy for juror bias)