Sanchez v. Roden
2014 U.S. App. LEXIS 9844
1st Cir.2014Background
- Sanchez was convicted of second-degree murder after a 2006 trial; jury selection included peremptory strikes by the Commonwealth.
- The prosecutor peremptorily struck several young men of color (including Juror No. 261, a 19‑year‑old Black college student); defense objected under Batson/Soares at the time of Juror 261's removal.
- The trial judge declined to require the prosecutor to articulate race‑neutral reasons; the Massachusetts Appeals Court affirmed, noting other Black jurors had been seated and treating age as the likely basis for strikes; the Massachusetts SJC denied further review.
- Sanchez sought federal habeas relief; the district court denied the petition but granted a COA; First Circuit reviewed de novo.
- The First Circuit held the MAC unreasonably applied Batson’s first prong (failed to consider all relevant circumstances and improperly relied on the presence of other Black jurors), found Sanchez made a prima facie showing, and remanded to the district court for an evidentiary hearing to complete the Batson inquiry.
Issues
| Issue | Sanchez's Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| Did Sanchez exhaust state remedies for his federal Batson claim? | He fairly and recognizably presented a federal Equal Protection/Batson claim in trial and on appeal. | The claim as presented varied ("men of color" v. "young Black men") so some formulations were unexhausted. | Exhaustion satisfied: courts fairly alerted to federal Batson claim; Commonwealth waived non‑exhaustion defense at district level. |
| Did the MAC unreasonably apply Batson's first prong? | MAC ignored relevant circumstances and improperly relied on fact other Black jurors were seated. | The presence of seated Black jurors and use of strikes against some young white jurors negated inference of racial motivation. | MAC unreasonably applied Batson by failing to consider all relevant circumstances; its analysis was objectively unreasonable. |
| Did Sanchez make a prima facie showing under Batson step one? | The pattern (three young Black men struck while a similarly situated young white man was seated) permitted an inference of discrimination. | The strikes were based on age (not a protected class) and the record shows non‑racial reasons. | Prima facie showing satisfied: similarly situated comparators and lack of evident nonracial basis supported an inference that discrimination may have occurred. |
| What is the appropriate remedy? | Require the prosecutor to state race‑neutral reasons and, if inadequate, grant a new trial. | Affirm conviction absent persuasive proof of discriminatory motive. | Remand to district court for an evidentiary hearing to complete Batson steps two and three; do not order a new trial at this stage. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (1986) (peremptory strikes based on race violate Equal Protection and set forth three‑step burden shifting test)
- Snyder v. Louisiana, 552 U.S. 472 (2008) (Constitution forbids striking even a single prospective juror for a discriminatory purpose; consider all circumstances)
- Powers v. Ohio, 499 U.S. 400 (1991) (defendant may raise third‑party juror equal protection claims even if juror and defendant differ in race)
- Miller‑El v. Dretke, 545 U.S. 231 (2005) (comparative juror analysis and statistics can demonstrate purposeful discrimination)
- Johnson v. California, 545 U.S. 162 (2005) (prima facie burden at step one is low; consider totality of circumstances)
- Cullen v. Pinholster, 563 U.S. 170 (2011) (limits on evidentiary development in habeas but does not foreclose remand when state court unreasonably applied federal law)