SUPREME COURT REJECTS DRUG DEFENDANT'S
RACIAL BIAS CLAIM
In a unanimous decision announced today, the United States Supreme
Court reinstated the drug possession conviction of a Southern California
man. The Court's decision in Rice v. Collins overturned an earlier
federal Ninth Circuit Court of Appeals ruling which concluded that the
prosecutor discriminated against blacks during jury selection. Prior
decisions by the trial judge, a state appellate court, and the Federal
District Court had rejected the criminal's racial bias claim.
The Sacramento-based Criminal Justice Legal Foundation had submitted
an amicus curiae (friend of the Court) brief in the case arguing
that to reach its ruling the Ninth Circuit misapplied precedent and
rules limiting its authority and requiring deference to a trial court's
credibility finding. Today's unanimous decision utilized arguments
from that brief.
In the Court's eight-page opinion, Justice Anthony Kennedy wrote, "Concerned
that, in this habeas corpus case, a federal court set aside reasonable
state-court determinations of fact in favor of its own debatable interpretation
of the record, we granted certiorari. Our review confirms that the Court
of Appeals for the Ninth Circuit erred, misapplying settled rules that
limit its role and authority."
"In 1996 Congress enacted rules which limit the ability of the
lower federal courts to overturn state court decisions simply because
they disagree with the conclusion," said Charles Hobson, author
of the Foundation's brief. "Today's Supreme Court decision makes
it clear that the reasonable decisions of the state courts are to be
respected," he added.
The case involves the conviction of Steven Collins for possession of
rock cocaine. After finding that Collins had prior convictions of robbery
and forcible rape, which qualified him for a third strike under California
law, the judge sentenced Collins to 25 years to life.
During jury selection, the prosecutor used two of his peremptory challenges
to dismiss black prospective jurors, but did not challenge two other
blacks who ultimately served and participated in the trial. When the
two blacks were challenged, Collins asked the judge to rule that the
prosecutor violated the prohibition against racial bias in jury selection
established by the 1987 case of Batson v. Kentucky. The judge
held a hearing to determine the basis for the prosecutor's challenges,
found them reasonable, and ruled that there was no racial bias.
Following his conviction and sentence, Collins appealed, claiming that
the trial judge had violated his rights by allowing jury discrimination.
The state Court of Appeal rejected this claim, applying California precedent
which gives great deference to the trial court's finding of fact with
regard to bias claims. After the state Supreme Court denied review,
Collins petitioned the Federal District Court to uphold his claim. On
habeas corpus, the District Court conducted a full review and found
the claim meritless. Collins then appealed to the Ninth Circuit. On
November 3, 2003, a Ninth Circuit panel reversed the lower courts by
a 2-1 vote. The opinion, authored by Judge Richard Paez, reconsidered
the facts surrounding the prosecution's jury challenges and came to
a different conclusion than the trial judge. The opinion also found
the decisions of the state courts unreasonable.
In CJLF's brief, the Foundation argued that both the Batson
decision and the Antiterrorism and Effective Death Penalty Act of 1996
require the federal courts to give great deference to the trial judge's
determination of the facts. The Ninth Circuit's ruling ignored this
prohibition and reconsidered the facts several years after the trial,
without the benefit of actually seeing the challenged jurors or hearing
their responses to questions. The Foundation's brief pointed out that
the deference requirement was imposed specifically to prevent federal
courts from second-guessing the judges actually presiding over the trial,
who are far better qualified to evaluate the facts.
"The Supreme Court's decision in this case confirms that, with
regard to claims of bias during jury selection, federal judges are not
free to substitute their own views, years after the trial, for the fact-based
findings of the trial judge who was actually there," said Hobson.
CJLF Attorney Charles Hobson is available for comment
at (916) 446-0345.
The Criminal Justice Legal Foundation helped win seven United States
Supreme Court decisions benefitting law enforcement and public safety
during the Court's 2004/05 term.
The Foundation's brief is available at:
http://www.cjlf.org/briefs/Collins.pdf
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