McDaniels v. Kirkland

Petitioners, convicted of first degree murder, appealed their separate district court judgments denying their 28 U.S.C. 2254 habeas petitions. At issue was petitioners' Batson v. Kentucky argument that the prosecutor excluded African-American jurors based on race during jury selection. The court held that the CCA did not unreasonably apply Batson when it did not sua sponte augment the record so as to allow for comprehensive comparative juror analysis; the court could only review the CCA's decision under 28 U.S.C. 2254(d)(2) in light of the evidence before it, and because it was undisputed that the first day of voir dire and the questionnaires were not in the record, the court could not include them in its analysis of whether the CCA made unreasonable factual findings; and, in regards to the partial voir dire and Batson hearing transcript, petitioners have not demonstrated that the CCA made an unreasonable determination of fact in light of the evidence before it. Accordingly, the court affirmed the district court's denial of the habeas corpus petitions. View "McDaniels v. Kirkland" on Justia Law