(CN) – The Supreme Court on Monday reversed a 5th Circuit’s order granting a new trial to a death-row inmate, after the prosecutor struck a black juror based on her “somewhat humorous” demeanor. The justices said the appeals court misinterpreted precedent as requiring the trial judge to reject the prosecutor’s demeanor-based explanation.
In ordering a new trial for Anthony Cardell Haynes, the 5th Circuit found that the Supreme Court’s ruling in Batson v. Kentucky requires a trial judge to reject a demeanor-based explanation for a peremptory challenge, unless the judge “personally observed and recalls the juror’s demeanor.”
In Haynes’ case, different trial judges oversaw the voir dire and the peremptory challenge stages of the trial. The judge overseeing the challenges had accepted the prosecutor’s claim that the juror’s demeanor revealed a “predisposition” against capital punishment. Thus, the prosecutor’s reason for the strike was “race-neutral,” the judge determined.
Haynes was convicted and sentenced to death, and the Texas Court of Criminal Appeals affirmed the conviction.
The 5th Circuit in New Orleans reversed, however, saying the trial judge must “verify the aspect of the juror’s demeanor upon which the prosecutor based his or her peremptory challenge.”
But in the Supreme Court’s view, this was an incorrect application of precedent.
“Batson plainly did not go further and hold that a demeanor-based explanation must be rejected if the judge did not observe or cannot recall the juror’s demeanor. Nor did we establish such a rule in Synder,” the court added, referring to its 2008 ruling in Synder v. Louisiana.
The justices sent the case back to the 5th Circuit, instructing it to reconsider the appeals court’s decision.