Sanchez v. Roden, No. 13-1394 (1st Cir. 2014)
Annotate this CaseAfter a jury trial, Petitioner was found guilty of second degree murder and unlawful possession of a firearm. Petitioner appealed his conviction, contending that the Commonwealth used its peremptory challenges to exclude young African Americans in violation of the equal protection principles laid down in Batson v. Kentucky. The Massachusetts Appeals Court (MAC) concluded that Petitioner had failed to make a prima facie showing that the Commonwealth’s use of peremptory challenges was likely motivated by the jurors’ race. Petitioner failed to obtain relief on appeal in the Massachusetts courts and subsequently sought a writ of habeas corpus from the United States District Court. The district court denied the petition. The First Circuit vacated the judgment of the district court, holding that the MAC’s application of the first Batson prong was clear error and represented an objectively unreasonable application of clearly established federal law. Remanded to the district court to conduct an evidentiary hearing and to complete the Batson inquiry.
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