Amador v. Anderson

CourtDistrict Court, W.D. Washington
DecidedAugust 8, 2025
Docket2:24-cv-00737
StatusUnknown

This text of Amador v. Anderson (Amador v. Anderson) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Amador v. Anderson, (W.D. Wash. 2025).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 DANIEL S. AMADOR II, CASE NO. CV24-00737 8 Petitioner, ORDER 9 v. 10 LISA ANDERSON, 11 Respondent. 12

13 This matter comes before the Court on Magistrate Judge Brian A. Tsuchida’s 14 Report and Recommendation (R&R) recommending that the Court deny and dismiss with 15 prejudice petitioner Amador’s petition for writ of habeas corpus and decline to issue a 16 certificate of appealability. Dkt. 23. 17 The parties agree that the R&R accurately details the underlying facts leading to 18 Amador’s conviction and the procedural history of this case. Dkt. 23 at 1–5. The Court 19 incorporates by reference that overview here. 20 21 22 1 The thorough R&R rejects each of Amador’s four grounds for habeas relief. 2 Amador makes numerous and at times repetitive and overlapping objections to the 3 R&R’s analysis. A summary of the R&R’s conclusions and Amador’s objections follows:

4 (1) Public trial right 5 Amador asserts that the trial court violated his Sixth Amendment public trial right 6 while the parties discussed and reached an agreement on the challenge for cause of a 7 juror. Dkt. 3 at 5. The juror commented on how common it was for sexual abuse to occur 8 in Latino homes. The trial court granted a defense motion to examine whether the

9 comment tainted the panel. The prosecutor verbally endorsed that juror’s commentary, 10 and the court interrupted the parties’ discussion and called a recess. While in recess the 11 parties reached an agreement to excuse the prospective juror for cause. No court reporter 12 was present to record the agreement. 13 The R&R correctly concludes Amador waived his public trial right claim because

14 he did not object to the manner of the discussion about the prospective juror, nor raise a 15 Sixth Amendment claim on direct review. Dkt. 23 at 12. It concludes that Amador failed 16 to distinguish his case from the Supreme Court’s ruling in Levine v. United States, 362 17 U.S. 610, 619 (1960) (defendant can waive the public trial right guarantee by failing to 18 object to closure of the proceedings). Id. It found that Amador “points to no evidence in

19 the record of any action taken by the trial court to ‘close’ the courtroom” and that his 20 “speculation and inuendo” is insufficient. Id. at 13. 21 Amador objects to these conclusions. He argues that the R&R mistook the record 22 because there were “significant changes in the State’s position that occurred during the 1 recess and outside of the public eye” because the prosecutor no longer opposed 2 dismissing the juror for cause after the recess. Dkt. 24 at 4. He objects to the R&R’s 3 conclusion that Levine governs his case and that he failed to establish the trial court

4 closed the courtroom. He asserts that Levine is distinguishable in part because the 5 petitioner there “had no right to have the general public present while the grand jury’s 6 questions were being read.” Id. In contrast, he argues that there was plainly impermissible 7 secrecy in his proceedings because “an agreement was made outside the presence of the 8 public and where there is no court reporter reporting what the parties stated.” Id. at 6.

9 (2) Peremptory challenge procedure 10 Amador asserts that the trial court’s peremptory challenge procedure denied equal 11 protection, due process, and fair and impartial jury in violation of Sixth and Fourteenth 12 Amendments. Dkt. 3 at 7. The trial court used General Rule (GR) 37, which establishes a 13 framework more protective than Batson for evaluating bias in the use of a peremptory

14 challenge. Under GR 37, a party may object to the use of a peremptory challenge on the 15 basis of bias, the party exercising the challenge must articulate the reasons for using the 16 peremptory challenge, and the trial court must determine whether an objective observer 17 could view race or ethnicity as a factor in the use of the peremptory challenge; if the trial 18 court finds in the affirmative on that question, it must deny the peremptory challenge. GR

19 37(c)-(e). The trial court may initiate this analysis on its own. GR 37(c). 20 Like the state appellate courts before it, the R&R acknowledged that the trial court 21 misinterpreted GR 37 in its instructions to the parties when it asserted that that GR 37 22 applied to “persons of color or of ethnicity other than white,” that the rule focused on 1 “groups who have been discriminated against recently,” and that Jews were not included 2 in GR 37 protections. Dkt. 23 at 18. It concluded however that Amador “fails to provide 3 any argument or explanation to support a finding the state courts’ determination that this

4 error made no difference in the case was unreasonable.” Id. at 19. It reasoned further that 5 Amador lacks “United States Supreme Court precedent supporting a contention that an 6 error in implementing state law peremptory challenge procedures is a violation of federal 7 law when there is no evidence that the error affected the assessment of any peremptory 8 challenges.” Id. Finally, it reasoned that there is “nothing in the record to indicate the

9 parties were precluded from bringing a motion under Batson with respect to any 10 peremptory challenge or that the trial court would not have ruled on a motion brought 11 under Batson that was outside the bounds of its GR 37 ruling.” Id. at 20. 12 Amador objects to these findings. He reiterates his argument that the fact that the 13 trial court’s procedure violated GR 37 “destroyed” the framework for evaluating bias and

14 is a sufficient “structural error” for an Equal Protection and Due Process violation. Dkt. 15 24 at 11. He asserts that the error did “make a difference in his case” because with a 16 structural error, “harm is presumed” and the state court’s decision that the errors made no 17 difference is therefore an unreasonable application of federal law. He asserts that he need 18 not provide a Supreme Court case with a similar fact pattern to support his position. Id. at

19 11–13 (citing Windham v. Merkle, 163 F.3d 1092, 1096 (9th Cir. 1998) ((constitutional 20 error in jury selection is structural)). He counters the R&R’s point that nothing precluded 21 him from making a Batson motion by asserting that he “did not have to” because GR 37 22 is “meant to provide better protection against discrimination” than Batson. Id. at 15. 1 (3) Peremptory challenges of Asian American jurors 2 Amador contends the prosecutor’s peremptory strikes of two Asian American 3 jurors (numbers 12 and 63) violated equal protection by demonstrating racial bias in

4 violation of Sixth Amendment. Dkt. 3 at 8. Regarding juror 12, the R&R concluded that 5 Amador’s “[p]ointing to reasons the trial court could have denied the peremptory does 6 not establish that it was unreasonable for the court to credit the prosecutor’s race-neutral 7 explanation.” Dkt. 23 at 25. Regarding juror 63, it noted that Amador did not object to the 8 use of a peremptory challenge, but rather the trial court conducted a GR 37 analysis on its

9 own motion. Id. at 26. As with juror 12, the R&R concluded that Amador did not 10 establish that the state courts’ decision to credit the prosecutor’s race-neutral explanations 11 was unreasonable. Id. at 28. 12 Amador objects to these conclusions. He argues that the state courts failed to 13 discern the possibility of discriminatory intent, and that because the two peremptory

14 strikes of Asian-Americans occurred under the structurally defective GR 37 framework, 15 the strikes were constitutionally defective.

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Amador v. Anderson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/amador-v-anderson-wawd-2025.