Thaler v. Haynes (2009)
- Docket
- 09-273
- Decided
- 2009-01-01
Summary
Question: 1) Does Batson v. Kentucky entitle a defendant to a new trial because the trial judge observed the prosecutor's explanation for the juror strike but did not observe the jury interviews? 2) Does Snyder v. Louisiana entitle a defendant to a new trial -- even when a prosecutor struck a prospective juror based on her friendly demeanor to defense counsel and not race -- because the trial judge observed the prosecutor's explanation for the strike but did not observe the jury interviews? Conclusion: No and No. In a per curiam opinion, the Supreme Court reversed the Fifth Circuit and held that neither Batson nor Snyder require that a demeanor-based explanation must be rejected if the judge did not observe or cannot recall the juror's demeanor. The Court remanded the case to the Fifth Circuit for proceedings consistent with the opinion. Moreover, the Court instructed that the Fifth Circuit may consider whether the Texas Court of Criminal Appeals' determination may be overcome under the federal habeas statute's standard for reviewing a state court's resolution of questions of fact.