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Name: Rice v. Collins
Case #: Apr-52
Court: US Supreme Court
District USSup
Opinion Date: 01/18/2006
Summary

A trial court’s ruling that a prosecutor’s challenge to an African-American juror was race-neutral was not the result of an unreasonable factual determination. After the prosecutor used a peremptory challenge to strike an African-American juror from the panel, the defense raised a Batson challenge. The prosecutor claimed that the challenge was due to the juror’s youth and gender, and to the fact that she rolled her eyes during questioning. The California Court of Appeal affirmed, holding that the juror’s demeanor was a sufficiently race-neutral basis to justify the challenge. A federal district court dismissed the defendant’s petition for writ of habeas corpus, but the Ninth Circuit granted relief, holding that the state court’s decision was based on an unreasonable factual determination. The Supreme Court reversed, finding that the Ninth Circuit had used debatable inferences in determining that the factual determination of the state court was unreasonable and improperly substituted its own evaluation of the record for that of the state court. Although reasonable minds reviewing the record could disagree as to the prosecutor’s credibility, federal habeas relief requires a showing that the factual determination in the state court was unreasonable.