Scott v. Arnold, No. 18-16761 (9th Cir. 2020)
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The Ninth Circuit reversed the district court's grant of habeas relief to petitioner, who was convicted of first degree murder. Petitioner moved for a new trial based on his discovery that a juror had made a false representation during voir dire.
The panel applied review under the Antiterrorism and Effective Death Penalty Act (AEDPA), holding that it was not unreasonable for the state court to conclude that McDonough Power Equipment, Inc. v. Greenwood, 464 U.S. 548 (1984), which permits a new trial where a juror's lies during voir dire hide a fact that would have permitted the juror to be stricken for cause, accommodates a prejudice analysis. Because the Supreme Court has not given explicit direction as to whether McDonough requires a criminal defendant to show prejudice to obtain a new trial, and because the state court's interpretation is consistent with many other courts' interpretations, the panel cannot hold that the state court's interpretation was contrary to, or involved an unreasonable application of, Supreme Court precedent.
Court Description: Habeas Corpus. The panel reversed the district court’s judgment granting Rickey Leon Scott’s habeas corpus petition in a case in which Scott, who was convicted of first-degree murder, moved for a new trial based on his discovery that a juror had made a false representation during voir dire. The trial court denied the motion, and the California Court of Appeal affirmed, holding that McDonough Power Equipment, Inc. v. Greenwood, 464 U.S. 548 (1984), which permits a new trial where a juror’s lies during voir dire hide a fact that would have permitted the juror to be stricken for cause, accommodates a prejudice analysis. The district court held that McDonough could not accommodate a prejudice analysis. Applying AEDPA review, the panel held that it was not unreasonable for the state court to conclude that McDonough accommodates a prejudice analysis, as McDonough did not explain if, or demonstrate through application whether, it was establishing a simple binary test or a test that accommodates a prejudice analysis. The panel observed that fairminded disagreement exists as to the application of McDonough, and therefore concluded that the state court did not reach a decision contrary to clearly established Supreme Court precedent. SCOTT V. ARNOLD 3
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