Ricky D. Adkins v. Warden, Holman CF
710 F.3d 1241
11th Cir.2013Background
- Adkins, a white Alabama death-row inmate, challenged the state’s use of peremptory strikes to remove black jurors in his capital murder trial.
- During voir dire, nine of eleven black veniremembers were struck, leaving only one black juror on the panel.
- Alabama law at the time barred a white defendant from challenging the state’s peremptory strikes; no contemporaneous objection was raised at trial.
- Post-Powers, Alabama Supreme Court remanded for Batson-type proceedings; Batson hearings evaluated whether strikes were race-based.
- At remand, the state presented race-neutral reasons; the trial court found no Batson violation, affirmed on appeal.
- Petitioners sought federal habeas relief under 28 U.S.C. § 2254; the district court denied Batson relief but granted a COA, which this court reversed on the Batson issue and remanded for writ conditioned on retry.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the state court's Batson ruling was an unreasonable application of federal law | Adkins contends Batson was misapplied due to incomplete consideration of all circumstances | State argues state court’s Batson analysis was within accepted standards and deference applies | Batson third-step not properly applied; AEDPA deference does not apply; relief granted |
| Whether the Alabama courts reasonably determined the facts supporting Batson discrimination | Adkins argues key facts show purposeful discrimination were ignored | State asserts factual findings were reasonable | State court factual determinations were unreasonable under 28 U.S.C. § 2254(d)(2) |
| Whether a contemporaneous objection rule barred federal review of Batson claims | Adkins did not object at trial but Alabama remanded; his claim should be reviewable on the merits | State relies on contemporaneous-objection-based waiver and procedural defaults | Contemporaneous objection rule did not bar merits-review; the claim was properly before the federal court |
| Whether AEDPA requires deference to state court rulings on Batson claims | Adkins asserts state court misapplied Batson and AEDPA permits de novo review | State maintains AEDPA deference applies to state court adjudications | AEDPA does not bar de novo review where state court unreasonably applied Batson |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (establishes three-step Batson framework and requirement of nondiscriminatory jury selection)
- Powers v. Ohio, 499 U.S. 400 (U.S. 1991) (defendant may object to race-based juror exclusions regardless of race)
- Miller-El I, 537 U.S. 322 (U.S. 2003) (emphasizes considering all relevant circumstances in Batson third step)
- McGahee v. Alabama Dep't of Corr., 560 F.3d 1252 (11th Cir. 2009) (failure to consider all relevant circumstances at Batson third step = unreasonable application)
- Harrington v. Richter, 131 S. Ct. 770 (U.S. 2011) (definition of AEDPA deference and merits review in § 2254(d))