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.
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Wednesday, January 18, 2006
Wednesday, January 11, 2006
In Brown v. Sanders, No. 04-980 (Jan. 11, 2006), the Supreme Court held that a death penalty jury’s consideration of aggravating factors which were later invalidated by the State’s Supreme Court did not unconstitutionally deprive the defendant to an individualized death sentence. The Court noted that the (new) test for such issues is that invalidated sentencing factor will render a death sentence unconstitutional by reason of its adding an improper element to the aggravation scale in the weighing process, unless one of the other sentencing factors enables the sentencer to give aggravating weight to the same facts and circumstances. In this case, even though two factors were invalidated, the broad instruction to give weight to the "circumstances of the crime" enabled the sentencer to give weight the same facts and circumstances. Hence, the sentence was valid.
In Evans v. Chavis, No. 94-721 (Jan. 10, 2006), the Supreme Court, applying Carey v. Saffold, 536 U.S. 214 (2002), held that a state post-conviction proceeding cannot be considered "pending" and thereby toll the one-year AEDPA statute of limitations, when the petitioner delayed for over three years filing his appeal in the California Supreme Court from an adverse decision, and did not have an adequate excuse to explain his inaction during this entire period. The Court reversed the Ninth Circuit’s contrary holding.