The Supreme Court on Monday reinstated a California man’s convictions on several sex offenses stemming from his 2002 attack on a 72-year-old neighbor, overturning an appeals court that found prosecutors impermissibly rejected two potential jurors based on their race.
The jury that convicted Steven Frank Jackson in 2004 contained just one black person. Jackson is black; his victim was white.
The trial court, a state appellate panel and a U.S. District judge on post-conviction review all rejected Jackson’s Batson challenge, accepting the prosecutor’s race-neutral explanations for not seating the two potential jurors.
Last year, though, the 9th U.S. Circuit Court of Appeals found Jackson was entitled to a new trial, issuing a very short opinion that concluded the race-neutral explanations were pretextual.
The Supreme Court faulted the 9th Circuit’s decision in a five-page per curiam opinion on Monday.
“That decision is as inexplicable as it is unexplained,” the justices said. “It is reversed.”
By law, the 9th Circuit should have given far more deference to the state-court determinations, the Supreme Court held.
“The state appellate court’s decision was plainly not unreasonable,” the opinion says. “There was simply no basis for the Ninth Circuit to reach the opposite conclusion, particularly in such a dismissive manner.”
The case is Felkner v. Jackson, 10-797.