| Rice v. Collins | |
|---|---|
 | |
| Argued December 5, 2005 Decided January 18, 2006 | |
| Full case name | Rice, Warden, et al. v. Collins |
| Docket no. | 04-52 |
| Citations | 546U.S.333 (more) 126 S. Ct. 969; 163L. Ed. 2d 824; 2006U.S. LEXIS 913 |
| Case history | |
| Prior | Superior Court of California convicted defendant; California Court of Appeal upheld conviction,People v. Collins, No. B106939 (Dec. 12, 1997); Supreme Court of California denied petition for review; United States District Court for the Central District of California dismissed with prejudice respondent's petition for a writ of habeas corpus; reversed, 348F.3d1082 (9th Cir. 2003);cert. granted,545 U.S. 1151 (2005). |
| Holding | |
| Habeas corpus relief may not be granted on the basis of debatable inferences used to overturn the trial court's finding. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Kennedy, joined byunanimous |
| Concurrence | Breyer, joined by Souter |
| Laws applied | |
| 28 U.S.C. § 2254(d)(2) | |
Rice v. Collins, 546 U.S. 333 (2006), was a decision by theSupreme Court of the United States regarding aprosecutor's use of aperemptory challenge to remove a youngAfrican American woman, Juror 16, from a defendant's drug trialjury in aCalifornia court case, based on her youth and on her alleged "eye rolling" in answer to a question.[1][2][3] The defendant, Steven Martell Collins, challenged the striking of Juror 16, saying her exclusion was based onrace, but the trialjudge agreed that the prosecutor's reasons were race-neutral. TheCalifornia Court of Appeal upheld the trial court's ruling, and theFederal District Court dismissed Collins'habeas corpus petition with prejudice. However, theNinth Circuit Court of Appeals reversed andremanded, stating that the dismissal was unreasonable based, among other reasons, on the lack ofevidence that the eye rolling had occurred.[4]
InBatson v. Kentucky (1986) the Supreme Court ruled that a prosecutor cannot systematically use peremptory challenges to strike jurors based on race. The court set forth a three-step process in evaluating claims of discrimination. First, the defendant must present reasons that support the contention that the prosecutor's peremptory challenges were based on race. Second, the State must produce race-neutral explanations for the peremptory challenge. Third, the trial court must determine if the peremptory challenges were based on race or on other factors. InGeorgia v. McCollum (1992) the Court ruled that the three-step procedure applied equally to the defense, and inJ.E.B. v. Alabama ex rel. T.B. (1994) to challenges based on gender.[5] However the Court has always held,inter alia, the ultimate burden of proving or disproving racial motivation for the strike always falls on the party challenging the strike.[1]
Steven Martell Collins, an African American male, was on trial in thesuperior court ofLos Angeles County, California, for possession of drugs with intent to distribute. Because he was ahabitual criminal, he was eligible for California'sThree Strikes sentencing law. Duringjury selection, theprosecutor removed an African American woman, Juror 16, on a peremptory challenge. When Collins contended that the juror was removed because of her race, the prosecutor listed race-neutral reasons for the challenge. These reasons included that the juror had "rolled her eyes" in response to a question, that because of her youth she may be tolerant of drugs, and that she lacked sufficient ties to the community.[1] The trial court stated that it did not see the rolling of the eyes by Juror 16 but agreed that she was youthful, and while noting that a white male juror was also dismissed for being youthful, ruled it would give the prosecutor "the benefit of the doubt" and allow the juror strike to stand.[1] Collins was convicted and received a 25-yearsentence.
Collins appealed his case to theCalifornia Courts of Appeal claiming his rights had been violated by the trial judge in allowing jury discrimination. The Court of Appeal rejected this claim, using the precedent giving greater deference to the trial court's finding regarding claims of racial bias. After theCalifornia Supreme Court denied review, Collins filed a petition forhabeas corpus in the Federal District Court. The District Court conducted a full review and found the claim was without merit.
TheNinth Circuit Court of Appeals reviewed the evidence and concluded that, since the trial court had not witnessed Juror 16's alleged "eye rolling", that the trial judge erred in accepting the prosecutor's version of the eye rolling incident. It noted that the prosecutor's credibility had been previously undermined by other erroneous statements. For example, the prosecutor said that Juror 19, another prospective African-American juror, was too youthful despite the fact that she was a grandmother and attempted to use gender as a basis for exclusion. On this basis, the court overturned Collins' conviction.
The U.S. Supreme Court granted a writ ofcertiorari.
The Supreme Court held that the Ninth Circuit's "attempt to use a set of debatable inferences to set aside the conclusion" fails to satisfy theAntiterrorism and Effective Death Penalty Act of 1996.[1] The Court unanimously reversed andremanded, stating "Reasonable minds reviewing the record might disagree about the prosecutor's credibility, but on habeas review that does not suffice to supersede the trial court's credibility determination."[1]
This article incorporatespublic domain material from this U.S government document.