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Name: Lewis v. Lewis
Case #: 01-56927
Court: US Court of Appeals
District 9 Cir
Opinion Date: 02/28/2003
Subsequent History: None

The California Court of Appeal constitutionally erred, warranting reversal under AEDPA, when it affirmed the trial court’s denial of a Batson/Wheeler motion. In a highly fact-dependent case, the trial court failed to conduct a proper inquiry for the third step in that it did not find the prosecutor very credible, since it rejected some of the offered reasons, and its own description of the one explanation that was “probably reasonable” was conflicting. This explanation had to do with the fact that the prospective juror’s niece and nephew “may” have worked in a jail, which was only a possibility. Moreover, the Court of Appeal relied on an alternative explanation in upholding the decision, which was that the prospective juror appeared to be a “loner” who did not relate easily to other jurors. However, because the trial court did not specify which of the reasons it found “not convincing,” the reason was not necessarily race-neutral, and because it depended upon the prosecutor’s credibility, the state appellate court could not properly rely on this ground.