Snyder v. Louisiana

552 U.S. 472, 128 S. Ct. 1203, 170 L. Ed. 2d 175, 2008 U.S. LEXIS 2708
CourtSupreme Court of the United States
DecidedMarch 19, 2008
Docket06-10119
StatusPublished
Cited by1,264 cases

This text of 552 U.S. 472 (Snyder v. Louisiana) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Snyder v. Louisiana, 552 U.S. 472, 128 S. Ct. 1203, 170 L. Ed. 2d 175, 2008 U.S. LEXIS 2708 (2008).

Opinions

Justice Auto

delivered the opinion of the Court.

Petitioner Allen Snyder was convicted of first-degree murder in a Louisiana court and was sentenced to death. He asks us to review a decision of the Louisiana Supreme Court rejecting his claim that the prosecution exercised some of its peremptory jury challenges based on race, in violation of Batson v. Kentucky, 476 U. S. 79 (1986). We hold that the trial court committed clear error in its ruling on a Batson objection, and we therefore reverse.

I

The crime for which petitioner was convicted occurred in August 1995. At that time, petitioner and his wife, Mary, had separated. On August 15, they discussed the possibility of reconciliation, and Mary agreed to meet with petitioner the next day. That night, Mary went on a date with Howard Wilson. During the evening, petitioner repeatedly attempted to page Mary, but she did not respond. At approximately 1:30 a.m. on August 16, Wilson drove up to the home of Mary’s mother to drop Mary off. Petitioner was waiting at the scene armed with a knife. He opened the driver’s side door of Wilson’s car and repeatedly stabbed the occu[475]*475pants, killing Wilson and wounding Mary. The State charged petitioner with first-degree murder and sought the death penalty based on the aggravating circumstance that petitioner had knowingly created a risk of death or great bodily harm to more than one person. See La. Code Crim. Proc. Ann., Art. 905.4(A)(4) (West Supp. 2008).

Voir, dire began on Tuesday, August 27, 1996, and proceeded as follows. During the first phase, the trial court screened the panel to identify jurors who did not meet Louisiana’s requirements for jury service or claimed that service on the jury or sequestration for the duration of the trial would result in extreme hardship. More than 50 prospective jurors reported that they had work, family, or other commitments that would interfere with jury service. In each of those instances, the nature of the conflicting commitments was explored, and some of these jurors were dismissed. App. 58-164.

In the next phase, the court randomly selected panels of 13 potential jurors for further questioning. Id., at 166-167. The defense and prosecution addressed each panel and questioned the jurors both as a group and individually. At the conclusion of this questioning, the court ruled on challenges for cause. Then, the prosecution and the defense were given the opportunity to use peremptory challenges (each side had 12) to remove remaining jurors. The court continued this process' of calling 13-person panels until the jury was filled. In accordance with Louisiana law, the parties were permitted to exercise “backstrikes.” That is, they were allowed to use their peremptories up until the time when the final jury was sworn and thus were permitted to strike jurors whom they had initially accepted when the jurors’ panels were called. See La. Code Crim. Proc. Ann., Art. 795(B)(1) (West 1998); State v. Taylor, 93-2201, pp. 22-23 (La. 2/28/96), 669 So. 2d 364, 376.

Eighty-five prospective jurors were questioned as members of a panel. Thirty-six of these survived challenges for [476]*476cause; 5 of the 36 were black (as is petitioner); and all 5 of the prospective black jurors were eliminated by the prosecution through the use of peremptory strikes. The jury found petitioner guilty of first-degree murder and determined that he should receive the death penalty.

On direct appeal, the Louisiana Supreme Court conditionally affirmed petitioner’s conviction. The court rejected petitioner’s Batson claim but remanded the case for a nunc pro tunc determination of petitioner’s competency to stand trial. State v. Snyder, 98-1078 (La. 4/14/99), 750 So. 2d 832. Two justices dissented and would have found a Batson violation. See id., at 866 (Johnson, J., dissenting), 863 (Lemmon, J., concurring in part and dissenting in part).

On remand, the trial court found that petitioner had been competent to stand trial, and the Louisiana Supreme Court affirmed that determination. State v. Snyder, 1998-1078 (La. 4/14/04), 874 So. 2d 739. Petitioner petitioned this Court for a writ of certiorari, and while his petition was pending, this Court decided Miller-El v. Dretke, 545 U. S. 231 (2005). We then granted the petition, vacated the judgment, and remanded the case to the Louisiana Supreme Court for further consideration in light of Miller-El. Snyder v. Louisiana, 545 U. S. 1137 (2005). On remand, the Louisiana Supreme Court again rejected Snyder’s Batson claim, this time by a vote of 4 to 3. See 1998-1078 (La. 9/6/06), 942 So. 2d 484. We again granted certiorari, 551 U. S. 1144 (2007), and now reverse.

II

Batson provides a three-step process for a trial court to use in adjudicating a claim that a peremptory challenge was based on race:

“ ‘First, a defendant must make a prima facie showing that a peremptory challenge has been exercised on the basis of race[; sjecond, if that showing has been made, [477]*477the prosecution must offer a race-neutral basis for striking the juror in question!; and t]hird, in light of the parties’ submissions, the trial court must determine whether the defendant has shown purposeful discrimination.’” Miller-El v. Dretke, supra, at 277 (Thomas, J., dissenting) (quoting Miller-El v. Cockrell, 537 U. S. 322, 328-329 (2003)).

On appeal, a trial court’s ruling on the issue of discriminatory intent must be sustained unless it is clearly erroneous. See Hernandez v. New York, 500 U. S. 352, 369 (1991) (plurality opinion); id., at 372 (O’Connor, J., joined by Scalia, J., concurring in judgment). The trial court has a pivotal role in evaluating Batson claims. Step three of the Batson inquiry involves an evaluation of the prosecutor’s credibility, see 476 U. S., at 98, n. 21, and “the best evidence [of discriminatory intent] often will be the demeanor of the attorney who exercises the challenge,” Hernandez, 500 U. S., at 365 (plurality opinion). In addition, race-neutral reasons for peremptory challenges often invoke a juror’s demeanor (e. g., nervousness, inattention), making the trial court’s firsthand observations of even greater importance. In this situation, the trial court must evaluate not only whether the prosecutor’s demeanor belies a discriminatory intent, but also whether the juror’s demeanor can credibly be said to have exhibited the basis for the strike attributed to the juror by the prosecutor. We have recognized that these determinations of credibility and demeanor lie “‘peculiarly within a trial judge’s province,’ ” ibid, (quoting Wainwright v. Witt, 469 U. S. 412

Free access — add to your briefcase to read the full text and ask questions with AI

Related

People v. Wright
42 N.Y.3d 708 (New York Court of Appeals, 2024)
David Thomas v. State of Mississippi
249 So. 3d 331 (Mississippi Supreme Court, 2018)
Grant v. Royal
886 F.3d 874 (Tenth Circuit, 2018)
Commonwealth v. Edwards
177 A.3d 963 (Superior Court of Pennsylvania, 2018)
Com. v. Edwards, D.
Superior Court of Pennsylvania, 2018
Doreen Smith v. Roger Jones
Sixth Circuit, 2018
JOEL I. JONES v. STATE OF FLORIDA
229 So. 3d 834 (District Court of Appeal of Florida, 2017)
Ann Catherine Reese v. State
Court of Appeals of Texas, 2017
City of Seattle v. Erickson
Washington Supreme Court, 2017
People v. Howard-Walker
2017 COA 81 (Colorado Court of Appeals, 2017)
People v. Gutierrez
California Supreme Court, 2017
United States v. Anthem, Inc.
855 F.3d 345 (D.C. Circuit, 2017)
People v. Douglas
California Court of Appeal, 2017
Ryan Black v. Amy Miller
Ninth Circuit, 2017

Cite This Page — Counsel Stack

Bluebook (online)
552 U.S. 472, 128 S. Ct. 1203, 170 L. Ed. 2d 175, 2008 U.S. LEXIS 2708, Counsel Stack Legal Research, https://law.counselstack.com/opinion/snyder-v-louisiana-scotus-2008.