On March 21, 2011, the U.S. Supreme Court decided Felkner v. Jackson, No. 10-797, holding that the Ninth Circuit Court of Appeals had failed to apply the established deferential standard of review for habeas corpus petitions under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) and had improperly reversed a district court's denial of such a petition based on a Batson challenge.
Defendant Steven Jackson was convicted of numerous sexual offenses in California state court. Jackson raised a Batson challenge based on the prosecution's peremptory exclusion from the jury of two of the three prospective black jurors, claiming that the reasons given by the prosecution were pretextual. After the California trial and appellate courts rejected his challenge, Jackson brought a petition for habeas corpus relief in federal district court. The district court denied the petition, but the Ninth Circuit reversed in an unpublished three-paragraph decision. The Ninth Circuit's decision did not discuss the reasoning of the prior courts that had considered the Batson issue.
In a per curiam decision, the Supreme Court reversed. The Court's brief decision faulted the Ninth Circuit for ignoring the standard of review established by the AEDPA, which permits the grant of a habeas petition only where the state court action "resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding." Finding no basis for any conclusion of such an "unreasonable determination" and noting the Ninth Circuit's "dismissive manner," the Court reversed the Ninth Circuit's judgment and remanded for further proceedings consistent with its decision.