Aleman v. Uribe

A defendant’s constitutional rights are not violated when a state court denies a Batson motion based on a prosecutor’s credible explanation that he made an “honest mistake” in exercising a peremptory challenge.

Raymond Maldonado and Mario Aleman were involved in an armed robbery and ambush on police officers. The prosecutor exercised peremptory challenges on Hispanic jurors at voir dire during their joint trial. The defense objected to the fourth preemptory challenge, claiming purposeful discrimination under Batson v. Kentucky. The prosecutor explained his concerns about sensitivity due to a “prissy” comment. The judge denied the Batson challenge, concluding there were “valid, race-neutral justifications.” Later, the judge found that it was not the dismissed juror who made the “prissy” comment. The prosecutor explained that he must have confused two jurors due to their close proximity and similar sensitive characteristics. The trial court determined the exclusion “was based on an ‘honest mistake’ and not racial bias.” Both Maldonado and Aleman were convicted. The California Court of Appeal affirmed the convictions and upheld the Batson ruling. After their 28 U.S.C. § 2254 Petitions for Writ of Habeas Corpus in the U.S. District Court for the Eastern District of California were denied, the Ninth Circuit granted both Maldonado and Aleman a certificate of appealability on the Batson claims. In its fact-based inquiry, the panel determined that the record contained ample support for the trial court’s finding that the prosecutor’s mistake was credible, honest, and unintentional and that the California Court of Appeal was not objectively unreasonable to affirm the trial court’s Batson ruling based on the fact that “an honest mistake is not evidence of racial bias.” The panel held that by denying a Batson motion based on “a prosecutor’s credible explanation” that he simply made an “honest mistake,” a state court does not violate a defendant’s constitution rights.” AFFIRMED.