McDaniels v. Kirkland, No. 09-17339 (9th Cir. 2014)
Annotate this CasePetitioners, convicted of first degree murder, appealed their separate district court judgments denying their 28 U.S.C. 2254 habeas petitions. At issue was petitioners' Batson v. Kentucky argument that the prosecutor excluded African-American jurors based on race during jury selection. The court held that the CCA did not unreasonably apply Batson when it did not sua sponte augment the record so as to allow for comprehensive comparative juror analysis; the court could only review the CCA's decision under 28 U.S.C. 2254(d)(2) in light of the evidence before it, and because it was undisputed that the first day of voir dire and the questionnaires were not in the record, the court could not include them in its analysis of whether the CCA made unreasonable factual findings; and, in regards to the partial voir dire and Batson hearing transcript, petitioners have not demonstrated that the CCA made an unreasonable determination of fact in light of the evidence before it. Accordingly, the court affirmed the district court's denial of the habeas corpus petitions.
Court Description: Habeas Corpus. The panel affirmed the district court’s judgments denying two California state prisoners’ 28 U.S.C. § 2254 habeas corpus petitions arguing, based on Batson v. Kentucky, that the prosecutor excluded African-American jurors based on race during jury selection. The panel held that the California Court of Appeal (CCA) did not unreasonably apply Batson when it did not sua sponte augment the record so as to allow for comparative juror analysis, and that its failure to augment the record therefore did not negate the deference usually due state courts in federal habeas proceedings. The panel wrote that it can only review the CCA’s decision under 28 U.S.C. § 2254(d)(2) in light of the evidence before the CCA, and because it is undisputed that the first day of voir dire and jury questionnaires were not in the record, the panel cannot include them in its analysis of whether the CCA made unreasonable factual findings. Because the district court made no finding that the petitioners had been diligent in pursuing questionnaires or that the limitations set forth in 28 U.S.C. § 2254(e)(2) were met, the panel explained that 28 U.S.C. § 2254(e)(1) did not provide an avenue for considering the questionnaires. Turning to the partial voir dire and the Batson hearing transcript, as the circumstantial and direct evidence of intent that was before the CCA, the panel concluded that the CCA’s decision upholding the trial court’s finding that the prosecutor did not exclude jurors based on race was not unreasonable.
The court issued a subsequent related opinion or order on February 26, 2015.
The court issued a subsequent related opinion or order on December 24, 2015.
The court issued a subsequent related opinion or order on December 24, 2015.
The court issued a subsequent related opinion or order on October 14, 2016.
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