Today’s Opinion in Rice v. Collins

Today, in a unanimous opinion, the Supreme Court reversed the Ninth Circuit’s determination that a California trial court had unreasonably dismissed a Batson challenge to the striking of an African American juror. Justice Kennedy, delivering the opinion of the Court, explained that the Court had granted certiorari specifically because it was concerned that “in this habeas corpus case, a federal court set aside reasonable state-court determinations of fact in favor of its own debatable interpretation of the record.”

Under AEDPA, as codified at 28 U.S.C. 2254(d)(2), federal courts reviewing the credibility findings made by a state trial court in a Batson challenge may grant relief only if they determine that the state court’s conclusion was “an unreasonable determination of the facts.” (This standard of review applies only to habeas petitions. On direct appeal from a state court, the standard of review is “clear error.”) A separate provision of the AEDPA, codified at 28 U.S.C. 2254(e)(1), imposes an even higher standard on certain claims. It deems state-court factual findings presumptively correct; a habeas petitioner can overcome that presumption only with “clear and convincing” evidence. The Court found it unnecessary to consider which provision of the AEDPA applied to the respondent’s case, explaining that the Ninth Circuit’s holding was untenable even under the lower standard of §2554(d)(2) because the state court’s findings were not unreasonable. The Ninth Circuit’s concerns about the prosecutor’s race-neutral explanation, even if given “the most generous reading,” suggested only that the trial court had reason to question the prosecutor’s credibility. It did not compel the conclusion that the trial court’s only permissible alternative was to reject the prosecutor’s race-neutral justification and find a Batson violation.

Justice Breyer issued a concurring opinion in which he restated his position, first expressed in Miller-El v. Dretke (2005), that the Batson test and the preemptory challenge system generally should be reconsidered. In perhaps the most interesting development in the case, Justice Souter, the author of the majority opinion in Miller-El, joined in Justice Breyer’s concurrence.

For more background to the case, see SCOTUSblog’s preview of the argument and its coverage of oral argument.