Rice v. White
2011 U.S. App. LEXIS 21464
| 6th Cir. | 2011Background
- Rice and Knight were charged with first-degree murder and firearm possession in Michigan; tried jointly in Wayne County; jury selection spanned July 26–28, 1999; defense alleged Batson race-based strikes against Black jurors Johnson, Jones, Bonner; trial court initially rejected Batson, later questions arose about essential findings; Michigan Supreme Court remanded for reconsideration of Batson issue in 2003; on remand, Michigan Court of Appeals and Michigan Supreme Court issued decisions up to 2005; district court granted a conditional writ under 28 U.S.C. § 2254, finding Batson violation and improper factual determinations by the state courts; the Sixth Circuit affirmed the district court’s grant of habeas relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Michigan Supreme Court’s Batson ruling was based on unreasonable factual determinations under §2254(d)(2). | Rice contends trial court erred in discrediting prosecutor’s race-neutral reasons for strikes Johnson and Jones. | White argues the Michigan Supreme Court correctly concluded there was no Batson violation. | Yes; state court factual determinations were unreasonable under §2254(d)(2). |
| Whether the Batson violation violated Rice’s Fourteenth Amendment equal protection rights. | Rice asserts purposeful discrimination occurred in striking Johnson and Jones. | White maintains no Batson violation occurred due to adequate record and balancing considerations. | Yes; Batson violation occurred, violating equal protection. |
| What is the appropriate remedy for the Batson violation in this habeas context? | Remedy should be retry of Rice within 180 days as the district court suggested. | Remedy not explicitly addressed; state court failure to cure Batson taint. | Issue resolved by ordering a conditional writ directing retry within 180 days or release. |
| Did the trial court comply with Batson’s three-step framework at the time of the proceedings? | Trial court failed to properly conduct step three and erred in accepting/assessing reasons. | Prosecutor provided neutral reasons; court evaluated them. | Trial court violated Batson procedures; proper step-three finding of discrimination. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (1986) (prohibition on racially-motivated peremptory strikes; three-step Batson framework)
- Miller-El v. Dretke, 545 U.S. 231 (2005) (under Batson, credibility of race-neutral reasons evaluated on record)
- Braxton v. Gansheimer, 561 F.3d 453 (6th Cir. 2009) (deference to trial court credibility in Batson determinations; de novo review may apply post‑AEDPA)
- Harrington v. Richter, 131 S. Ct. 770 (2011) (AEDPA deference limits; Supreme Court elaborates review standards for unreasonable determinations of law and fact)
- Hill v. Mitchell, 400 F.3d 308 (6th Cir. 2005) (discusses de novo review when state court adjudication is not on the merits or AEDPA exceptions apply)