MILLER-EL V. DRETKE 545 U.S. 231 (2005) CASE BRIEF

MILLER-EL V. DRETKE

545 U.S. 231 (2005)

NATURE OF THE CASE: This was an appeal from a denial of habeas corpus relief for using peremptory challenges to racially bias a jury.

FACTS: Miller-El (D) and his accomplices bound and gagged two hotel employees. D then shot, killing one and severely injuring the other. During D's trial for capital murder, prosecutors used peremptory strikes against 10 qualified black venire members. D objected that the strikes were based on race and could not be presumed legitimate, given a history of excluding black members from criminal juries by the Dallas County District Attorney's Office. The trial court found no 'systematic exclusion of blacks as a matter of policy' by that office. The court denied D's request to pick a new jury, and the trial ended with his death sentence for capital murder. While an appeal the Supreme Court decided Batson v. Kentucky. The Texas Court of Criminal Appeals remanded to the trial court to determine whether D could show that prosecutors in his case peremptorily struck prospective black jurors because of race. The trial court accepted the stated race-neutral reasons for the strikes, which the judge called 'completely credible [and] sufficient' as the grounds for a finding of 'no purposeful discrimination.' The Court of Criminal Appeals affirmed, stating it found 'ample support' in the voir dire record for the race-neutral explanations offered by prosecutors for the peremptory strikes. D then sought habeas relief under 28 U. S. C. 2254, again presenting his Batson claim. The District Court denied relief and the Court of Appeals for the Fifth Circuit precluded appeal by denying a certificate of appealability. The Supreme Court granted certiorari to consider whether D was entitled to review on the Batson claim. It reversed the Court of Appeals. After examining the record of D's extensive evidence of purposeful discrimination by the Dallas County District Attorney's Office before and during his trial, it found an appeal was in order, since the merits of the Batson claim were, at the least, debatable by jurists of reason. After granting a certificate of appealability, the Fifth Circuit rejected D's Batson claim on the merits. The Supreme Court again granted certiorari.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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