Jamerson v. Runnels

In order to overrule the trial court's determination on the credibility of racially discriminatory preemptory challenges, there must be sufficient evidence that the trial court erred.

Keith Jamerson was charged in California state court with one count of unlawful driving or taking of a vehicle and one count of receiving stolen property. During jury selection, Jamerson raised two objections against the prosecutor’s use of preemptory strikes against black jurors under Baston v. Kentucky and its California equivalent, People v. Wheeler. The California Supreme Court denied review, following Jamerson’s direct appeal to the California Court of Appeals where the lower court’s decision was upheld. Jamerson then filed a petition for habeas corpus in the federal district court, which purported that the California courts were wrong to deny Jamerson’s Baston/Wheeler motions, which resulted in habeas relief being granted for Jamerson. The State appealed and asserted that the district court erred by granting Jamerson’s habeas petition and argued that the courts acted reasonably to determine that the prosecutor was not engaged in purposeful discrimination. Following an analysis of Jamerson’s petition under the framework set out by the Anti-terrorism and Effective Death Penalty Act, 28 U.S.C. § 2254, the Ninth Circuit held that the prosecutor’s conduct was not enough to find that the state court acted unreasonably when the courts upheld the prosecutor’s race-neutral justifications for the strikes when challenged under Baston/Wheeler. Even though reasonable minds who were reviewing the record could disagree regarding the prosecutor’s credibility, the evidence contained in the record was not sufficient to overrule the trial court’s credibility determination. REVERSED.