Miller-El v. Dretke
Miller-El v. Dretke | |
---|---|
![]() | |
Argued December 6, 2004 Decided June 13, 2005 | |
Full case name | Miller-El v. Dretke, Director, Texas Department of Criminal Justice, Correctional Institutions Divisions |
Citations | 545 U.S. 231 (more) 125 S. Ct. 2317; 162 L. Ed. 2d 196; 2005 U.S. LEXIS 4658; 73 U.S.L.W. 4479; 18 Fla. L. Weekly Fed. S 376 |
Case history | |
Prior | 361 F.3d 849 (5th Cir. 2004); cert. granted, 542 U.S. 936 (2004). |
Holding | |
The prosecution in the capital trial of Miller-El violated the Fourteenth Amendment as interpreted in Batson v. Kentucky when it racially discriminated against black potential jurors, and Miller-El is entitled to habeas corpus relief. | |
Court membership | |
| |
Case opinions | |
Majority | Souter, joined by Stevens, O'Connor, Kennedy, Ginsburg, Breyer |
Concurrence | Breyer |
Dissent | Thomas, joined by Rehnquist, Scalia |
Laws applied | |
U.S. Const. amend. XIV |
Miller-El v. Dretke, 545 U.S. 231 (2005), is a United States Supreme Court case that clarified the constitutional limitations on the use by prosecutors of peremptory challenges and of the Texas procedure termed the "jury shuffle."[1]
Background
[edit]Thomas Miller-El was charged with capital murder committed in the course of a robbery. After voir dire, Miller-El moved to strike the entire jury because the prosecution had used its peremptory challenges to strike ten of the eleven African-Americans who were eligible to serve on the jury. This motion was denied, and Miller-El was subsequently found guilty and sentenced to death.
Opinion of the Court
[edit]In 1986, the Supreme Court ruled in Batson v. Kentucky that a prosecutor's use of peremptory challenges may not be used to exclude jurors on the basis of race. Miller-El appealed based on the Batson criteria and asked that his conviction be overturned. In June 2005, the Supreme Court ruled 6–3 to overturn Miller-El's death sentence, finding his jury selection process had been tainted by racial bias.
The Court had held in Batson that a defendant could rely on "all relevant circumstances" in making out a prima facie case of purposeful discrimination. Miller-El clarified that "all relevant circumstances" included evidence outside "the four corners of the case."[2] Specifically, the Court allowed statistical analysis of the venire,[3] side-by-side comparison of struck and empaneled jurors,[4] disparate questioning,[5] and evidence of historical discrimination.[6]
The Court extended the holding of Miller-El in Snyder v. Louisiana.
References
[edit]External links
[edit]- Text of Miller-El v. Dretke, 545 U.S. 231 (2005) is available from: Cornell CourtListener Google Scholar Justia Oyez (oral argument audio)