Batson v. Kentucky, 476 U.S. 79 (1986), was a landmark decision of the United States Supreme Court ruling that a prosecutor's use of a peremptory challenge in a criminal case—the dismissal of jurors without stating a valid cause for doing so—may not be used to exclude jurors based solely on their race. The Court ruled that this practice violated the Equal Protection Clause of the Fourteenth Amendment. The case gave rise to the term Batson challenge, an objection to a peremptory challenge based on the standard established by the Supreme Court's decision in this case. Subsequent jurisprudence has resulted in the extension of Batson to civil cases and cases where jurors are excluded on the basis of sex.
The right of peremptory challenge is a legal right in jury selection for the attorneys to reject a certain number of potential jurors or judges without stating a reason. The idea behind peremptory challenges is that if both parties have contributed in the configuration of the jury, they will find its verdict more acceptable. The use of peremptory challenges is controversial as some feel it has been used to undermine the balanced representation on a jury which would occur using random selection. Many jurisdictions limit or prohibit peremptory challenges.
Benton v. Maryland, 395 U.S. 784 (1969), is a Supreme Court of the United States decision concerning double jeopardy. Benton ruled that the Double Jeopardy Clause of the Fifth Amendment applies to the states. In doing so, Benton expressly overruled Palko v. Connecticut.
Miller-El v. Dretke, 545 U.S. 231 (2005), is a United States Supreme Court case that clarified the constitutional limitations on the use by prosecutors of peremptory challenges and of the Texas procedure termed the "jury shuffle."
Swain v. Alabama, 380 U.S. 202 (1965), was a case heard before the Supreme Court of the United States regarding the legality of a struck jury.
Griffith v. Kentucky, 479 U.S. 314 (1987), is a case decided by the United States Supreme Court.
Edmonson v. Leesville Concrete Company, 500 U.S. 614 (1991), was a United States Supreme Court case which held that peremptory challenges may not be used to exclude jurors on the basis of race in civil trials. Edmonson extended the court's similar decision in Batson v. Kentucky (1986), a criminal case. The Court applied the equal protection component of the Due Process Clause of the Fifth Amendment, as determined in Bolling v. Sharpe (1954), in finding that such race-based challenges violated the Constitution.
Rice v. Collins, 546 U.S. 333 (2006), was a decision by the Supreme Court of the United States regarding a prosecutor's use of a peremptory challenge to remove a young African American woman, Juror 16, from a defendant's drug trial jury in a California court case, based on her youth and on her alleged "eye rolling" in answer to a question. The defendant, Steven Martell Collins, challenged the striking of Juror 16, saying her exclusion was based on race, but the trial judge agreed that the prosecutor's reasons were race-neutral. The California Court of Appeal upheld the trial court's ruling, and the Federal District Court dismissed Collins' habeas corpus petition with prejudice. However, the Ninth Circuit Court of Appeals reversed and remanded, stating that the dismissal was unreasonable based, among other reasons, on the lack of evidence that the eye rolling had occurred.
J. E. B. v. Alabama ex rel. T. B., 511 U.S. 127 (1994), was a landmark decision of the Supreme Court of the United States holding that peremptory challenges based solely on a prospective juror's sex are unconstitutional. J.E.B. extended the court's existing precedent in Batson v. Kentucky (1986), which found race-based peremptory challenges in criminal trials unconstitutional, and Edmonson v. Leesville Concrete Company (1991), which extended that principle to civil trials. As in Batson, the court found that sex-based challenges violate the Equal Protection Clause.
Washington v. Recuenco, 548 U.S. 212 (2006), is the United States Supreme Court case of Recuenco, a man who was convicted of second-degree assault after he threatened his wife with a handgun, and subsequently sentenced by the Washington Supreme Court based not only on the conviction, but based on Recuenco's use of a handgun, charged as assault with a deadly weapon. His sentencing included a three-year enhancement, a standard based on his being armed with a firearm, which is greater than the one-year enhancement he would have received for assault with a deadly weapon. As the jury in the case had not found that Recuenco was armed with a firearm, he argued that the sentencing enhancement violated his Sixth Amendment right to a jury trial.
Hernandez v. New York, 500 U.S. 352 (1991), was a decision by the United States Supreme Court, which held that a prosecutor may dismiss jurors who are bilingual in Spanish and English from juries that will consider Spanish-language testimony.
Haywood v. Drown, 556 U.S. 729 (2009), was a United States Supreme Court case in which the Court held that a New York law preventing state trial courts from hearing claims for money damages against prison employees whether based on federal or state law violated the Supremacy Clause of the United States Constitution.
Teague v. Lane, 489 U.S. 288 (1989), was a United States Supreme Court case dealing with the application of newly announced rules of law in habeas corpus proceedings. This case addresses the Federal Court's threshold standard of deciding whether Constitutional claims will be heard. Application of the "Teague test" at the most basic level limits habeas corpus.
Snyder v. Louisiana, 552 U.S. 472 (2008), was a United States Supreme Court case about racial issues in jury selection in death penalty cases. Justice Samuel Alito, writing for the 7–2 majority, ruled that the prosecutor's use of peremptory strikes to remove African American jurors violated the Court's earlier holding in Batson v. Kentucky. Justice Clarence Thomas dissented.
Estelle v. Williams, 425 U.S. 501 (1976), is a Supreme Court case involving Harry Lee Williams' conviction of assault on his former landlord in Harris County, Texas. While awaiting trial Williams was unable to post bail. He was tried in his prison uniform, and later was found guilty. He sought a writ of habeas corpus saying being tried in a prison uniform violated his Constitutional rights in accordance with the 14th Amendment. The Court of Appeals ruled that the accused does not have to stand trial in identifiable prison clothes and Williams’ right to due process was violated. The Supreme Court reversed, reinstating the conviction, on June 21, 1976.
Davis v. Ayala, 576 U.S. 257 (2015), was a case in which the Supreme Court of the United States upheld a death sentence of a Hispanic defendant despite the fact that all Blacks and Hispanics were rejected from the jury during the defendant's trial. The case involved a habeas corpus petition submitted by Hector Ayala, who was arrested and tried in the late 1980s for the alleged murder of three individuals during an attempted robbery of an automobile body shop in San Diego, California in April 1985. At trial, the prosecution used peremptory challenges to strike all Black and Hispanic jurors who were available for jury service. The trial court judge allowed the prosecution to explain the basis for the peremptory challenges outside the presence of Ayala's counsel, "so as not to disclose trial strategy". Ayala was ultimately sentenced to death, but he filed several appeals challenging the constitutionality of the trial court's decision to exclude his counsel from the hearings.
Foster v. Chatman, 578 U.S. ___ (2016), was a United States Supreme Court case in which the Court held that the state law doctrine of res judicata does not preclude a Batson challenge against peremptory challenges if new evidence has emerged. The Court held the state courts' Batson analysis was subject to federal jurisdiction because "[w]hen application of a state law bar 'depends on a federal constitutional ruling, the state-law prong of the court’s holding is not independent of federal law, and our jurisdiction is not precluded,'" under Ake v. Oklahoma.
Flowers v. Mississippi, No. 17–9572, 588 U.S. ___ (2019), is a United States Supreme Court decision regarding the use of peremptory challenges to remove black jurors during a series of Mississippi criminal trials for Curtis Flowers, a black man convicted on murder charges. The Supreme Court held in Batson v. Kentucky that the use of peremptory challenges solely on the basis of race is unconstitutional. This case examined whether the Mississippi Supreme Court erred in how it applied Batson to this case. The Supreme Court ruled that Flowers' case fell under Batson and that the state inappropriately removed most of the potential black jurors during the trials.
Powers v. Ohio, 499 U.S. 400 (1991), was a United States Supreme Court case that re-examined the Batson Challenge. Established by Batson v. Kentucky, 476 U.S. 79 (1986), the Batson Challenge prohibits jury selectors from using peremptory challenges on the basis of race, ethnicity, gender, and sex. Powers expanded the jurisdictions of this principle, allowing all parties within a case, defendants especially, to question preemptory challenges during a jury selection, regardless of race. This holding was protected under the Equal Protection Clause of the Fourteenth Amendment.
Brown v. Davenport, 596 U.S. ___ (2022), was a case decided by the United States Supreme Court. The case concerned whether habeas relief may be granted if the Brecht v. Abrahamson test alone is satisfied, or if the application of Chapman v. California by the state courts was unreasonable because of AEDPA. The court held that federal courts can not grant habeas relief when state courts have already ruled on a prisoner's claim, unless the situation satisfies the test laid out in Brecht v. Abrahamson, and the test laid out in AEDPA.
