Woodfox v. Cain, et al., No. 13-30266 (5th Cir. 2014)Annotate this Case
The State appealed the district court's grant of habeas relief. On remand, the district court held that the state court was not entitled to Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. 2254, deference; petitioner had successfully made out a prima facie case of discrimination in the selection of the grand jury foreperson; and the State, acting through respondent, had failed to rebut the prima facie case. The court concluded that AEDPA deference is not warranted where the state court's decision was an unreasonable application of federal law; the district court did not err in finding that petitioner had made out his prima facie case; the State's attempt to rebut the prima facie case using statistics does not persuade and the district court did not err in finding as such; and the State has not demonstrated reversible error in the district court's holding that it failed to rebut the prima facie case. Accordingly, the court affirmed the judgment of the district court.
The court issued a subsequent related opinion or order on December 9, 2014.