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Wednesday, January 18, 2006

Rice v. Collins: AEDPA requires more Batson deference

In Rice v. Warden, No. 04-52 (Jan. 18, 2005), the Supreme Court reversed the Ninth Circuit grant of habeas relief based on a prosecutor’s use of a peremptory challenge in violation of Batson.
The Court explained that under AEDPA, a federal habeas court must find that a state court made an "unreasonable determination of facts" before it can overturn a state conviction and grant habeas relief. Here, the reasons given by the state trial court for finding that the prosecutor’s use of a peremptory challenge to dismiss a black juror were not so unreasonable as to warrant habeas relief. Reasonable minds reviewing the record might disagree with the state court’s credibility findings regarding the prosecutor’s reasons for dismissing the juror. But this does not suffice to supersede the trial court’s determination.