Sanchez v. Roden, No. 15-1197 (1st Cir. 2015)Annotate this Case
Appellant was indicted for second-degree murder and unlawful possession of a firearm. During jury selection for Appellant’s trial, the Massachusetts state prosecutor exercised peremptory challenge to strike three black men age twenty-five or under. The jury convicted Appellant, and he was sentenced to life imprisonment for murder. Appellant appealed, arguing that the prosecutor had improperly exercised peremptory challenges against young “men of color.” The appeals court affirmed. Appellant subsequently petitioned for a writ of habeas corpus in federal district court. The district court denied the petition, determining that the state court’s application of federal law was reasonable. The First Circuit remanded the case, concluding that Appellant had established a prima facie case of racial discrimination under step one of the framework established in Batson v. Kentucky. After an evidentiary hearing as to steps two and three of Batson, the district court ruled against Appellant on the final step of Batson. The First Circuit affirmed the district court’s denial of Appellant’s petition, holding that the district court did not abuse its discretion in concluding that Appellant had not proven that there was racial discrimination during jury selection.