Foster v. Chatman

Supreme Court of the United States · 2016 · Federal Courts

Federal CourtsBatsonadequate and independent state groundsequal protectionperemptory challengesBatsonperemptory strikespurposeful discrimination

Facts

At Foster's capital trial, the State used peremptory strikes against all four black prospective jurors who remained qualified to serve. In later state habeas proceedings, Foster obtained prosecution file materials showing repeated focus on race, including venire lists highlighting black jurors, notes labeling black jurors as "B#1," "B#2," and "B#3," a list of "definite NO's" containing all qualified black prospective jurors, notes marked "N" next to each black qualified juror, and a document stating "NO. NO Black Church." The prosecutors had previously offered race-neutral reasons for striking jurors Marilyn Garrett and Eddie Hood, including age, demeanor, family circumstances, and religion. The file materials and trial record undercut many of those explanations and showed that similar white jurors were accepted.

Issue

Whether the Supreme Court had jurisdiction despite the state habeas court's reference to res judicata, and whether the state courts clearly erred in concluding that Foster failed to show purposeful discrimination under Batson. More specifically, the Court considered whether the prosecution's strikes of black prospective jurors Marilyn Garrett and Eddie Hood were motivated in substantial part by discriminatory intent.

Rule

A state judgment does not bar Supreme Court review on adequate-and-independent-state-ground principles when the state-law ruling depends on a federal constitutional determination. Under Batson's third step, the court must determine whether the defendant proved purposeful discrimination, and all circumstances bearing on racial animosity must be considered; evidence that a prosecutor's stated reason applies equally to a similarly situated nonblack juror who was allowed to serve tends to show purposeful discrimination.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a capital case from Birmingham, Alabama, Devin Cole renewed an equal-protection objection to the prosecutor's jury strikes during state habeas proceedings after obtaining internal prosecution notes through a public-records request. The state habeas court said the claim was barred by state res judicata, but it then reviewed the trial record and the newly obtained notes, concluded the new materials did not show purposeful discrimination, and denied relief as meritless. The Alabama Supreme Court later denied discretionary review in a one-line order.

If Devin seeks review in the U.S. Supreme Court, is review most likely barred by an adequate and independent state ground?

Explanation. Review is not barred when the state-law ruling depends on resolving the federal constitutional question. Here, the habeas court did not simply invoke res judicata; it examined the record and new evidence to determine whether the renewed equal-protection claim had merit. That makes the state ground not independent of federal law. (Derived from Foster v. Chatman (n.d.).)