Under AEDPA, California Court of Appeal did not unreasonably approve the dismissal of a holdout juror for bias. During Williams’ trial for felony murder, the trial court dismissed a holdout juror, finding that the juror was biased. An alternate juror was seated and Williams was convicted. On appeal, Williams argued the dismissal of the holdout juror violated her Sixth Amendment rights and a state statute. The Court of Appeal affirmed and the California Supreme Court denied review. Williams sought habeas relief in the California courts and was unsuccessful. She filed a federal habeas petition and her case eventually went to the U.S. Supreme Court. The Court instructed the Ninth Circuit to review Williams’ Sixth Amendment claim under the AEDPA standard. Held: District court’s order denying habeas relief affirmed. The Ninth Circuit analyzed Williams’ three Six Amendment claims under AEDPA’s deferential standard of review (see 28 U.S.C. § 2254(d)) and determined that she was not entitled to relief. First, there is no U.S. Supreme Court precedent holding that a disruption of jury deliberations to inquire into potential juror bias violates the Sixth Amendment. Second, there is no U.S. Supreme Court precedent holding that dismissal of a juror violates the Sixth Amendment when it is reasonably possible that the impetus for the dismissal was the juror’s position on the merits of the case. Finally, the state appellate court’s finding that the holdout juror was biased because he would not follow the law was not an unreasonable determination of the facts in light of the evidence presented in the state court proceeding. Even though the trial court specifically stated that “not following the law is not a basis for [the holdout juror’s] dismissal,” the appellate court was entitled to make its own factual findings and its finding here was reasonable despite the trial court’s statement. [Editor’s Note: Judge Reinhardt dissented, concluding that the state appellate did make an unreasonable finding of fact.]

The full opinion is available on the court’s website here: https://cdn.ca9.uscourts.gov/datastore/opinions/2016/05/27/07-56127.pdf