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Name: Sims v. Rowland
Case #: 03-17256
Court: US Court of Appeals
District 9 Cir
Opinion Date: 07/20/2005

A state trial court’s failure to hold a hearing sua sponte to determine whether jurors’ fears regarding the defendant resulted in bias amounting to a due process violation was not a violation of clearly established federal law. Because the United States Supreme Court has not held that due process requires a trial court to hold a hearing sua sponte when evidence of jury bias has come to light, the federal courts may not grant habeas relief on that ground.