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Name: Davis v. Ayala
Case #: 13-1428
Court: US Supreme Court
District USSup
Opinion Date: 06/18/2015

State prisoner was not entitled to federal habeas relief because he failed to show that excluding defense counsel from part of a Batson v. Kentucky (1986) 476 U.S. 79 hearing was harmful under Brecht v. Abrahamson (1993) 507 U.S. 619 and AEDPA. During jury selection in Ayala’s triple murder trial, the prosecutor used seven peremptory challenges to strike all the African Americans and Hispanics who were available for service. Ayala objected under Batson and the trial court allowed the prosecution to provide its justification for striking the jurors outside the presence of the defense. The court found that the prosecutor had valid race-neutral reasons for the strikes. Ayala was convicted and a death sentence was imposed. On appeal, the California Supreme Court concluded that any federal error in excluding defense counsel from the Batson hearing was harmless beyond a reasonable doubt. Ayala raised this issue in a federal habeas petition, which the district court denied. The Ninth Circuit reversed, holding that the ex parte proceedings violated Ayala’s constitutional rights and that the error was not harmless as to at least three of the seven prospective jurors. The U.S. Supreme Court granted certiorari. Held: Reversed. A prisoner who seeks federal habeas corpus relief must establish that a trial error resulted in actual prejudice (the Brecht standard). If a state court concluded that a federal constitutional error was harmless under Chapman v. California (1967) 386 U.S. 18, the determination is reviewed under AEDPA and the prisoner must show that the state court applied Chapman in an objectively unreasonable manner. After reviewing the record and the California Supreme Court’s decision, the Court concluded that there was no basis for finding that Ayala suffered actual prejudice and that the state court’s decision was a reasonable application of controlling precedent. [Editor’s Note: In a concurring opinion, Justice Kennedy noted the problems with solitary confinement (an issue that was not presented in this case) and stated: “In a case that presented the issue, the judiciary may be required, within its proper jurisdiction and authority, to determine whether workable alternative systems for long-term confinement exist, and, if so, whether a correctional system should be required to adopt them.”]