Stenhouse v. Hobbs
631 F.3d 888
| 8th Cir. | 2011Background
- Stenhouse was convicted in Arkansas state court of capital murder and a firearm felony and sentenced to life without parole plus 15 years.
- The Arkansas Supreme Court affirmed; Stenhouse filed a 28 U.S.C. § 2254 petition in federal district court.
- District court denied relief but granted a certificate of appealability.
- Stenhouse alleged race-based peremptory jury strikes in violation of Batson v. Kentucky.
- Prosecutor struck three black venire members (Smith, Jackson, York); defense objected to Batson challenges.
- Arkansas Supreme Court held the strikes used race-neutral reasons and did not abuse discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the state courts unreasonably applied Batson to Smith | Stenhouse argues Batson was misapplied | Arkansas courts found race-neutral reasons and no purposeful discrimination | No; decision not contrary to clearly established law |
| Whether the strikes against Jackson and York were improper | Stenhouse contends race-based reasons were pretextual | State court found race-neutral explanations for Jackson and York | No; findings supported by record and not unreasonable |
| AEDPA deference and standard of review applied to Batson claims | State court misapplied federal law | State court correctly applied Batson framework | AEDPA standards satisfied; no unreasonable application or factual determination |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (1986) (prohibits race-based peremptory challenges; three-step framework)
- Miller-El v. Cockrell, 537 U.S. 322 (2003) (outlines Batson three-step analysis; applies to habeas)
- Snyder v. Louisiana, 552 U.S. 472 (2008) (requires explicit factual findings in some contexts; not mandate for every case)
- Purkett v. Elem., 514 U.S. 765 (1995) ( cautions against mixing Batson steps two and three)
- Smulls v. Roper, 535 F.3d 853 (2008) (en banc; supports deferential review of state court Batson rulings)
- Taylor v. Roper, 577 F.3d 848 (2009) (applies Batson framework; addresses deference in 8th Cir.)
- Miller-El v. Dretke, 545 U.S. 231 (2005) (reaffirmed Batson framework and ultimate burden on proponent of striking jurors)
- Joseph v. Coyle, 469 F.3d 441 (2006) (discusses appellate deference when state reasoning varies)