Johnson v. Finn

Due Process Clause requires the district court to hold a separate evidentiary hearing when rejecting a magistrate judge's ruling that the prosecution had racial motivation for excluding jurors.

Appellants, Johnson and Thompson were tried and found guilty of various crimes. During the jury selection phase of their trial they raised objections to the prosecution’s use of preemptory challenges against three African American jurors. The trial court found they had failed to make a showing that the prosecutor had an “invidious basis” for the peremptory challenges. After exhausting their remedies in state court they filed a petition for a writ of habeas corpus in federal court. After an evidentiary hearing, the magistrate judge ruled that the prosecutor had racial motivations for excluding one of the jurors. However, the district judge found, without an evidentiary hearing, that the prosecution had a valid “race-neutral reasons” for the exclusion. Johnson and Thompson appealed arguing that the district judge should have held a separate evidentiary hearing before rejecting the ruling of the magistrate judge. The Court held the rule in Ridgway extends to determinations by a magistrate judge as to the credibility of a prosecutor’s testimony at the second and third steps of inquiry required by Batson. Further, the Due Process clause, requires that the district court conduct a separate evidentiary hearing, allowing for observation of the prosecutor's demeanor while testifying, before rejecting a magistrate judge findings. VACATED AND REMANDED.