U.S. Supreme Court Upholds Government’s Juror Strike Based on Her Demeanor and Body Language – No Batson Violation

 

 On Feb. 22, 2010, the U.S. Supreme Court reversed a 5th U.S. Circuit Court of Appeals decision regarding the “demeanor-based” rejection of a potential juror in a death penalty case. Thaler v. Haynes involves a defense objection under Batson v. Kentucky (pdf) (1986) to the prosecution’s peremptory strike of a potential juror; Batson forbids striking potential jurors from a panel solely based on race.

The prosecution explained that it had struck the potential juror because she appeared not to be serious during questioning and her “body language” belied her “true feeling” about the death penalty, according to the opinion. The state trial court judge upheld the strike because the prosecution provided a race-neutral reason, but that judge did not observe the potential juror’s behavior.

The 5th Circuit in its Batson analysis ruled that it couldn’t defer to the state trial court’s decision because the judge didn’t see the potential juror’s demeanor. The 5th Circuit reversed a federal district court decision that had denied habeas relief, and it ordered a new trial.

The per curiam Supreme Court found that the 5th Circuit got it wrong when it looked at Batson and its progeny to arrive at the decision. “The Court of Appeals read far too much into those decisions, and its holding, if allowed to stand, would have important implications,” according to the high court decision, which reversed the 5th Circuit and remanded for proceedings consistent with its own opinion.

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