Crittenden v. Chappell

Petitioner was convicted of two murders and sentenced to death. Petitioner's first habeas petition, arguing that the prosecutor excluded an African-American prospective juror on account of her race, was denied by the district court, but this court remanded in light of Cook v. LaMarque, which clarified that a peremptory challenge violates the Equal Protection Clause if it is “motivated in substantial part” by race “regardless of whether the strike would have issued if race had played no role.” On remand, the district court found that the prosecutor was substantially motivated by race and granted petitioner habeas relief. On appeal, the state raised several challenges. The court affirmed the judgment, concluding that Cook merely clarified the standard of proof for Batson claims, but it did not set forth a new rule for purposes of Teague v. Lane; the California Supreme Court’s decision is not owed deference under the Antiterrorism and Death Penalty Act (AEDPA), 28 U.S.C. 2254, because it was contrary to clearly established federal law, and the presumption of correctness afforded to the state trial court’s factual findings is rebutted by clear and convincing evidence; the district court was not required to conduct its own evidentiary hearing, because it did not reject the magistrate judge’s credibility determination; and the district court’s finding that the prosecutor was substantially motivated by race was not clearly erroneous View "Crittenden v. Chappell" on Justia Law