Miller-El v. Dretke, 545 U.S. 231 (2005)
Primary Holding
Prosecutors' use of peremptory strikes in jury selection based on race violates the Equal Protection Clause of the Fourteenth Amendment, and a defendant is entitled to relief if they can demonstrate that such discrimination occurred.
In the case of Miller-El v. Dretke, a man named Thomas Joe Miller-El argued that the prosecutors unfairly excluded Black jurors from his trial based on their race. The Supreme Court agreed, stating that this kind of discrimination violates the law that protects everyone's right to a fair trial. This ruling helps ensure that all people, regardless of race, have an equal chance to serve on juries, which is important for fairness in the legal system. If someone feels they were treated unfairly in jury selection because of their race, this case can be relevant in supporting their claim.
AI-generated plain-language summary to help you understand this case
In late 1985, Thomas Joe Miller-El and his accomplices committed a robbery at a Holiday Inn in Dallas, Texas, during which they bound and gagged two hotel employees. Miller-El shot the employees, resulting in one death and severe injury to the other. During the subsequent capital murder trial, the prosecution exercised peremptory strikes against ten qualified black jurors. Miller-El objected, claiming that these strikes were racially motivated and indicative of a broader pattern of racial exclusion by the Dallas County District Attorney's Office. The trial court acknowledged evidence of past discriminatory practices but ultimately found no systematic exclusion of black jurors and denied Miller-El's request for a new jury. Following the trial, while Miller-El's appeal was pending, the Supreme Court issued a decision in Batson v. Kentucky, which altered the legal framework for addressing claims of racial discrimination in jury selection. The Texas Court of Criminal Appeals remanded the case to the trial court to reassess whether Miller-El could demonstrate that the prosecution's strikes were racially motivated. The trial court reviewed the voir dire record and accepted the prosecution's race-neutral explanations for the strikes, concluding that there was no purposeful discrimination. This decision was affirmed by the Court of Criminal Appeals. Miller-El subsequently sought habeas relief under 28 U.S.C. § 2254, continuing to assert his Batson claim among others. The District Court denied his request for relief, and the Fifth Circuit Court of Appeals denied a certificate of appealability, preventing Miller-El from appealing the decision. The Supreme Court eventually granted certiorari to review the case, focusing on the validity of Miller-El's claim regarding racial discrimination in jury selection.
Whether the prosecutors in Miller-El's capital murder trial engaged in racially discriminatory practices in their use of peremptory strikes against potential jurors, violating the Equal Protection Clause as established in Batson v. Kentucky.
s of Law Upon Remand from the Court of Criminal Appeals in State v. Miller-El, No. 8668–NL (5th Crim. Dist. Ct., Dallas County, Tex., Jan. 13, 1989), pp. 5–6, App. 928–929. The Court of Criminal Appeals affirmed, stating it found “ample support” in the voir dire record for the race-neutral explanations offered by prosecutors for the peremptory strikes. Miller-El v. State, No. 69,677 (Sept. 16, 1992) (per curiam) , p. 2, App. 931. Miller-El then sought habeas relief under 28 U. S. C. §2254, again pressing his Batson claim, among others not now before us. The District Court denied relief, Miller-El v. Johnson , Civil No. 3:96–CV–1992–H (ND Tex., June 5, 2000), App. 987, and the Court of Appeals for the Fifth Circuit precluded appeal by denying a certificate of appealability, Miller-El v. Johnson, 261 F. 3d 445 (2001). We granted certiorari to consider whether Miller-El was entitled to review on the Batson claim, Miller-El v. Cockrell,
- Court
- Supreme Court
- Decision Date
- December 6, 2004
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Souter
- Damages Awarded
- N/A
- Data Quality
- high
Johnson v. California, 545 U.S. 162 (2005)
Consumer WonTo establish a prima facie case of racial discrimination in jury selection under Batson v. Kentucky, a defendant does not need to show that it is more likely than not that the peremptory challenges were based on impermissible group bias; rather, the defendant must only demonstrate that the circumstances raise an inference of discrimination.
Dye v. Hofbauer, 546 U.S. 1 (2005)
Consumer WonFailure of a state appellate court to mention a federal claim does not mean that the claim was not presented to it, and the determination of whether the exhaustion requirement has been satisfied cannot depend solely on the state court's acknowledgment of the federal nature of the claim.
Brown v. Payton, 544 U.S. 133 (2005)
Consumer LostThe Supreme Court held that the Ninth Circuit's decision granting habeas relief was contrary to the limits on federal habeas review imposed by 28 U.S.C. § 2254(d), affirming that the jury instructions in the penalty phase of Payton's trial were not constitutionally deficient and did not prevent the jury from considering all relevant mitigation evidence.
Schriro v. Smith, 546 U.S. 6 (2005)
Consumer LostThe Ninth Circuit erred in requiring a jury trial to determine Smith's mental retardation claim, as states have the authority to develop their own procedures for adjudicating such claims, and the federal courts should not preemptively impose conditions on state proceedings.