Seals v. Vannoy, No. 19-30447 (5th Cir. 2021)Annotate this Case
The Fifth Circuit affirmed the district court's denial of habeas relief to petitioner, who was convicted of murder. Petitioner asserts that the State used race-based peremptory strikes during jury selection in violation of Batson v. Kentucky, 476 U.S. 79 (1986). The court concluded that the state appellate court did not unreasonably apply clearly established federal law in deciding petitioner's Batson claim by considering the jury panelists' voir dire answers among all the circumstances in deciding whether a prima facie case under Batson was shown. In this case, petitioner identifies no Supreme Court precedent clearly establishing that holistic consideration may not include the remarks of panelists on whom a peremptory strike was exercised. Nor does petitioner identify any evidence in the state court proceedings showing an unreasonable determination of fact by the state courts.
Moreover, circuit precedent holds that a prima facie case of purposeful discrimination under the Batson framework is a factual finding entitled to the section 2254(e)(1) presumption of correctness. The court concluded that the district court correctly stated the law in that regard. However, that presumption is not dispositive here because petitioner's habeas claim independently fails both under section 2254(d) and on de novo review. Finally, regardless of section 2254(d) and (e), petitioner must establish entitlement to habeas relief on the merits by showing, as relevant here, a violation of the constitutional right defined in Batson. In this case, petitioner failed to establish a prima facie case, and thus his claim for federal relief is foreclosed.