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Name: Briggs v. Grounds
Case #: 10-16683
Court: US Court of Appeals
District 9 Cir
Opinion Date: 06/15/2012

On federal habeas review of a Batson/Wheeler issue, the reviewing court must defer to the state court’s conclusion that there was no purposeful discrimination unless the state appellate court was objectively unreasonable in finding that the trial court’s credibility determination was supported by substantial evidence. At appellant’s trial, the prosecutor used 18 of her 20 peremptory challenges to strike three African-American prospective jurors and 15 non-African-American prospective jurors. The defense objected, claiming the challenges were racially motivated. The trial court found the prosecutor exercised her challenges for “non-race based reasons and they are valid.” The reasons included juror demeanor; requirement for additional evidence to convict; and inclination to hold the prosecution to a higher standard. The state appellate court considered comparative jury analysis in conjunction with its review of the individual jurors and found that substantial evidence supported the finding that the challenges were not race based. [With comparative analysis, if a prosecutor’s proffered reason for striking an African-American panelist applies just as well to an otherwise-similar non-African-American who is permitted to serve, that is evidence tending to prove purposeful discrimination.] The federal appellate court considered whether the state appellate court reasonably determined that the defendant had not established “purposeful discrimination.” In review, a federal habeas court can grant the petition only if it was unreasonable for the state court to credit the prosecutor’s race-neutral explanations for the Batson challenge. The state-court factual findings are presumed correct unless rebutted by clear and convincing evidence. Here, a review of the voir dire and the juror questionnaires by the federal court failed to reveal purposeful discrimination on the part of the prosecution in exercising peremptory challenges to strike the three African-American jurors.