February 22, 2010

Supreme Court Decides Thaler v. Haynes

On February 22, the Supreme Court decided Thaler v. Haynes, No. 09-273, holding that no previous decision of the Court "clearly establishes" a rule that a trial judge cannot accept a race-neutral explanation for a peremptory challenge to a prospective juror based on the juror's demeanor if the judge did not personally observe the demeanor.

Haynes was tried in a Texas state court for the murder of a police officer. Two different judges presided during portions of the voir dire. When the prosecutor struck an African-American juror from the jury panel and the defense objected that the strike was improperly motivated by race under Batson v. Kentucky, 476 U.S. 79 (1986), the prosecutor defended the strike as being based on the juror's "somewhat humorous" and "not serious" demeanor. The trial judge accepted the prosecutor's explanation as "race-neutral" and denied the challenge. The judge had not personally observed the juror's demeanor because he had not been presiding when the juror was examined. The trial proceeded, Haynes was convicted, and the Texas appellate courts affirmed his conviction, upholding the trial court's treatment of the Batson challenge.

Haynes then filed a federal habeas corpus petition. To obtain relief, he was required to show that the ruling of the Texas appellate court "was contrary to . . . clearly established Federal law, as determined by the Supreme Court." The federal district court denied the petition, noting that the Supreme Court had never held that this standard's deference to state-court fact-finding is inapplicable if the judge ruling on a Batson objection did not observe the jury selection. The U.S. Court of Appeals for the Fifth Circuit disagreed and ordered a new trial, holding that no deference to the state court's findings was appropriate when the trial judge could not personally verify the juror's demeanor that supposedly provided the race-neutral justification for the peremptory challenge.

In a unanimous per curiam opinion, the Supreme Court granted the petition for a writ of certiorari and reversed the Court of Appeals' judgment. It held that, although Batson requires a trial judge to take into account any observation of the juror that the judge was able to make during voir dire, no decision of the Court holds that such a prosecutor's explanation based on demeanor must always be rejected if the judge did not personally observe or cannot recall the juror's behavior. Nor has the Court held that a Batson challenge must be granted when different judges preside over various phases of the jury selection process. The Texas courts' rejection of the challenge here did not violate "clearly established Federal law," and the grant of habeas corpus relief was erroneous.

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