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Name: Boyd v. Newland
Case #: 03-17098
Court: US Court of Appeals
District 9 Cir
Opinion Date: 12/29/2004

A California court did not violate clearly established federal law by using a juvenile adjudication to enhance a sentence, even where that prior adjudication did not involve a jury trial. Although the Ninth Circuit has held that the exception in Apprendi v. New Jersey (2000) 530 U.S. 466 for prior convictions does not apply to non-jury adjudications, the Supreme Court has not so held and thus no federal habeas relief is available. Nor did the court violate clearly established federal law in applying the “strong likelihood” standard to a prima facie showing under Batson and Wheeler, since although the court used the “strong likelihood” language it nonetheless made the proper findings as required by Batson. Further, the court did not violate the defendant’s right to due process by denying him a full transcript of the voir dire proceedings where he had failed to make the showing required by a local rule. Finally, Supreme Court precedent does not require a full comparative analysis of all jurors in assessing a Batson claim.