Felkner v. Steven Frank Jackson

A California jury convicted respondent Steven Frank Jackson of numerous sexual offenses stemming from his attack on a 72-year-old woman who lived in his apartment complex. Jackson raised a Batson claim, asserting that the prosecutor exercised peremptory challenges to exclude black prospective jurors on the basis of their race [Batson v. Kentucky 476 U. S. 79 (1986)]. Two of three black jurors had been struck; the third served on the jury.

Jackson’s counsel did not object when the prosecutor struck the first of the black jurors but after the prosecutor sought to dismiss the second juror Jackson’s counsel made the Batson motion challenging both strikes. The prosecutor offered a race-neutral explanation for striking each juror. Jackson’s counsel expressly disagreed only with the prosecutor’s explanation for the strike of second juror but the trial court denied Jackson’s motion. Jackson renewed his Batson claim on direct appeal, arguing that a comparative juror analysis revealed that the prosecutor’s explanations were pre textual. The California Court of Appeal upheld the trial court’s denial of the Batson motion and affirmed Jackson’s convictions. The appellate court explained that the trial court’s ruling on the issue was reviewed for substantial evidence, which the California courts had characterized as equivalent to the “clear error” standard employed by federal courts. After the California Supreme Court denied Jackson’s petition for review, Jackson sought federal habeas relief. The Federal District Court properly recognized that review of Jackson’s claim was governed by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The District Court denied Jackson’s petition. The Court of Appeals for the Ninth Circuit reversed.

The Supreme Court held that on federal habeas review, AEDPA “imposes a highly deferential standard for evaluating state-court rulings” and “demands that state-court decisions be given the benefit of the doubt.” [Renico v. Lett(2010)]. The Supreme Court observed that in this case the trial court credited the prosecutor’s race-neutral explanations, and the California Court of Appeal carefully reviewed the record at some length in upholding the trial court’s findings. The state appellate court’s decision was plainly not unreasonable and there was simply no basis for the Ninth Circuit to reach the opposite conclusion. The petition for certiorari was thus granted and the judgment of the Court of Appeals for the Ninth Circuit was reversed, and the case was remanded for further proceedings consistent with the opinion.