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Monday, May 27, 2024 | Back issues
Courthouse News Service Courthouse News Service

9th Circuit Got It Wrong, U.S. Supreme Court Rules

(CN) - The U.S. Supreme Court on Monday overturned what it called an "inexplicable" decision by the 9th Circuit to grant habeas relief to a prisoner who was convicted of sexually attacking a 72-year-old woman. Steven Frank Jackson had claimed prosecutors improperly used peremptory strikes to keep black jurors off the trial.

In an unsigned, five-page decision, the justices chastised the San Francisco-based federal appeals panel for its "dismissive" finding.

At Jackson's trial for "numerous sexual offenses stemming from his attack on a 72-year-old woman who lived in his apartment complex," the prosecutor struck two of three black prospective jurors from the jury pool. A third black person served on the jury that convicted Jackson.

After the prosecutor removed the second black juror, Jackson's attorney challenged it and the previous strike. The prosecutor explained that he had a nonracial basis to exclude those individuals from the jury, noting that one may have harbored animosity toward police because he felt had been stopped unfairly between the ages of 16 and 30 because of his race and age. The second black juror struck off the jury, on the other hand, had performed social work in a prison.

The trial judge agreed that the strikes were not race motivated, and a California appeals court later upheld the strikes and affirmed Jackson's convictions.

After the state Supreme Court then denied Jackson's petition for review, however, the 9th Circuit reversed in a three-paragraph unpublished decision.

"In so doing, the court did not discuss any specific facts or mention the reasoning of the other three courts that had rejected Jackson's claim," the unsigned opinion states. "Instead, after setting forth the basic background legal principles in the first two paragraphs, the Court of Appeals offered a one-sentence conclusory explanation for its decision: 'The prosecutor's proffered race-neutral bases for peremptorily striking the two African-American jurors were not sufficient to counter the evidence of purposeful discrimination in light of the fact that two out of three prospective African-American jurors were stricken, and the record reflected different treatment of comparably situated jurors.'

"That decision is as inexplicable as it is unexplained," the Supreme Court's decision continues. "It is reversed."

The justices noted that the other courts to hear Jackson's claims reviewed the materials and credited the prosecutors' race-neutral explanations.

"The state appellate court's decision was plainly not unreasonable," according to the decision. "There was simply no basis for the Ninth Circuit to reach the opposite conclusion, particularly in such a dismissive manner."

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