Miller-El v. Dretke
Encyclopedia
Miller-El v. Dretke, 545 U.S. 231
(2005), is a decision by the Supreme Court of the United States
that clarified the constitutional
limitations on the use by prosecutors of peremptory challenges and of the Texas procedure appropriately termed the "jury shuffle."
, 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.
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 US 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." Specifically, the Court allowed statistical analysis of the venire, side-by-side comparison of struck and empaneled jurors, disparate questioning, and evidence of historical discrimination.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2005), is a decision by the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
that clarified the constitutional
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
limitations on the use by prosecutors of peremptory challenges and of the Texas procedure appropriately termed the "jury shuffle."
Factual background
Thomas Miller-El was charged with capital murder committed in the course of a robbery. After voir direVoir dire
Voir dire is a phrase in law which comes from the Anglo-Norman language. In origin it refers to an oath to tell the truth , i.e., to say what is true, what is objectively accurate or subjectively honest, or both....
, 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.
Decision
In 1986, the US Supreme Court ruled in Batson v. KentuckyBatson v. Kentucky
Batson v. Kentucky, , was a case in which the United States Supreme Court ruled that a prosecutor's use of peremptory challenge—the dismissal of jurors without stating a valid cause for doing so—may not be used to exclude jurors based solely on their race...
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 US 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." Specifically, the Court allowed statistical analysis of the venire, side-by-side comparison of struck and empaneled jurors, disparate questioning, and evidence of historical discrimination.