Sifuentes v. Brazelton, No. 13-17603 (9th Cir. 2016)
Annotate this CasePetitioner, on trial for first degree murder of a police officer, challenged the prosecutor’s decision to excuse nine black prospective jurors. Applying the doubly deferential standard for reviewing a Batson v. Kentucky determination, the court concluded that the California Court of Appeal’s decision was not based on an unreasonable determination of the facts. The court also concluded that the trial court’s decision to preclude petitioner from responding to the prosecutor’s race-neutral explanation for his strikes was harmless. Accordingly, the court reversed the district court's grant of habeas relief.
Court Description: Habeas Corpus. The panel reversed the district court’s judgment granting a habeas corpus petition in a case in which California state prisoner Miguel Galindo Sifuentes challenged the prosecutor’s decision to excuse nine black prospective jurors in his trial for first degree murder of a police officer. Applying the doubly deferential standard for reviewing a determination under Batson v. Kentucky, the panel held that the California Court of Appeal’s decision that Sifuentes had not carried his burden of showing the prosecutor acted in a purposefully discriminatory way was not based on an unreasonable determination of the facts. The panel also held that the trial court’s decision to preclude Sifuentes from responding to the prosecutor’s race-neutral explanation for his strikes was harmless. The panel remanded with instructions to dismiss the petition.
The court issued a subsequent related opinion or order on June 9, 2016.
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