Castellanos v. Small, No. 12-55783 (9th Cir. 2014)
Annotate this CasePetitioner was convicted in California state court of murder and related offenses. Petitioner appealed, arguing that the district court erred in denying his Batson motion because the prosecution engaged in purposeful discrimination when it exercised four peremptory strikes against Hispanic venirepersons. The California Court of Appeal affirmed the convictions. Thereafter, Petitioner applied for habeas relief. The district court denied the application, determining that the prosecutor’s use of peremptory challenges did not violate Petitioner’s federal constitutional right under the Fourteenth Amendment pursuant to Batson v. Kentucky. The Ninth Circuit reversed and remanded with instructions to grant the application, holding (1) under the totality of the circumstances, the prosecutor’s factually-erroneous reason for striking Venireperson 4968 was pretextual; and (2) the state court’s finding to the contrary amounted to an “unreasonable determination of the facts in light of the evidence presented.”
Court Description: Habeas Corpus. The panel reversed the district court’s judgment denying an application for habeas corpus, and remanded with instructions to grant the application, in a case in which the petitioner asserted that the prosecution engaged in purposeful discrimination in violation of Batson v. Kentucky when it exercised four peremptory strikes against Hispanic venirepersons. After reviewing the state court’s determination of no purposeful discrimination with respect to the striking of Venireperson 4968, together with a side-by-side comparison of the venirepersons at issue and the empaneled jurors, and other relevant circumstantial and direct evidence of intent to discriminate, the panel concluded that the prosecutor’s factually-erroneous stated reason for striking Venireperson 4968 – that she didn’t have children – was pretextual. The panel concluded that the petitioner’s state court proceedings resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented, 28 U.S.C. § 2254(d)(2), and that the district court therefore erred in denying the petitioner’s application for habeas relief.
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