Jamerson v. Runnels, No. 12-56064 (9th Cir. 2013)
Annotate this CasePetitioner was convicted of receiving stolen property. On appeal, the state challenged the district court's grant of his 28 U.S.C. 2254 habeas corpus petition based on Batson v. Kentucky. At issue was whether the California courts' determination that a prosecutor had genuine, race-neutral reasons for striking four black jurors during voir dire was an unreasonable application of federal constitutional law. As a threshold matter, the court held that Cullen v. Pinholster allowed the court to consider photographs that showed the racial composition of a jury venire to the extent that those photographs merely constructed facts visible to the state trial court that ruled on petitioner's Batson challenge. Overall, the evidence presented, including comparative analysis, did not persuade the court that habeas relief was warranted under the court's doubly deferential standard of review. Although some of the prosecutor's justifications appeared thin at first glance, a more searching review revealed nothing in the record suggesting that the state court unreasonably found these reasons to be genuine and not pretextual. Accordingly, the court reversed the district court's grant of habeas relief to petitioner.
Court Description: Habeas Corpus. The panel reversed the district court’s grant of a 28 U.S.C. § 2254 habeas corpus petition challenging a conviction of receiving stolen property based on Batson v. Kentucky, 476 U.S. 79 (1986). The panel first held that it was not precluded from considering the driver’s license photographs that showed the race of each venire member, to the extent that the photographs merely reconstructed facts visible to the state trial court that ruled on petitioner’s Batson challenge. In evaluating the Batson claim, the panel first performed the comparative analysis that the state court declined to pursue (because state law precluded such review for the first time on appeal). The panel then reevaluated the ultimate state decision in light of the comparative analysis and any other evidence tending to show purposeful discrimination, to decide whether the state was unreasonable in finding the prosecutor’s race-neutral justifications to be genuine. The panel concluded that, although some of the prosecutor’s justifications appeared thin at first glance, a more searching review revealed nothing in the record suggesting that the state court unreasonably found these reasons to be genuine and not pretextual.
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