Justia Constitutional Law Opinion Summaries

Defendant was convicted of two murders and sentenced to death. Defendant sought and was granted certiorari and the Supreme Court vacated the judgment and remanded the case to the court for reconsideration of defendant's United States v. Batson claim in light of the Court's intervening decision in Miller-El v. Dretke. The court remanded to the district court and the district court found that, even in light of the elucidation of Batson's principles in Miller-El, defendant had not met his burden of proving that the prosecution engaged in purposeful discrimination when it exercised peremptory strikes against five African-American members of the jury venire during jury selection for the sentencing phase in 2002. At issue was whether the district court's order denying relief of defendant's reconsidered Batson claim was proper. The court affirmed and held that there was no merit to defendant's contention that the district court committed prejudicial error in the manner in which it conducted the proceedings or in its findings of fact and legal conclusions on the merits of defendant's Batson claim.