Rice v. Collins
Encyclopedia
Rice v. Collins 546 U.S. 333
(2006), was a decision by the Supreme Court of the United States
regarding a prosecutor
's use of a peremptory challenge
to remove a young African American
woman, Juror 16, from a defendant's drug trial jury
in a California
court case, based on her youth and on her alleged "eye rolling" in answer to a question. The defendant, Steven Martell Collins, challenged the striking of Juror 16, saying her exclusion was based on race
, but the trial judge
agreed that the prosecutor's reasons were race-neutral. The California Court of Appeal upheld the trial court's ruling, and the Federal District Court
dismissed Collins' habeas corpus
petition with prejudice. However, the Ninth Circuit Court of Appeals
reversed and remanded, stating that the dismissal was unreasonable based, among other reasons, on the lack of evidence
that the eye rolling had occurred.
(1986) the Supreme Court ruled that a prosecutor cannot systematically use peremptory challenges to strike jurors based on race. The court set forth a three-step process in evaluating claims of discrimination. First, the defendant must present reasons that support the contention that the prosecutor's peremptory challenges were based on race. Second, the State must produce race-neutral explanations for the peremptory challenge. Third, the trial court must determine if the peremptory challenges were based on race or on other factors. In Georgia v. McCollum
(1992) the Court ruled that the three-step procedure applied equally to the defense, and in J.E.B. v. Alabama ex rel. T.B.
(1994) to challenges based on gender. However the Court has always held, inter alia
, the ultimate burden of proving or disproving racial motivation for the strike always falls on the party challenging the strike.
of Los Angeles County, California
for possession of drugs with intent to distribute. Because he was a habitual criminal, he was eligible for California's Three Strikes sentencing law
. During jury selection
, the prosecutor
removed an African American woman, Juror 16, on a peremptory challenge. When Collins contended that the juror was removed because of her race, the prosecutor listed race-neutral reasons for the challenge. These reasons included that the juror had "rolled her eyes" in response to a question, that because of her youth she may be tolerant of drugs, and that she lacked sufficient ties to the community. The trial court stated that it did not see the rolling of the eyes by Juror 16 but agreed that she was youthful, and while noting that a white male juror was also dismissed for being youthful, ruled it would give the prosecutor "the benefit of the doubt" and allow the juror strike to stand. Collins was convicted and received a 25-year sentence
.
in the Federal District Court. The District Court conducted a full review and found the claim was without merit.
The Ninth Circuit Court of Appeals
reviewed the evidence and concluded that, since the trial court had not witnessed Juror 16's alleged "eye rolling", that the trial judge erred in accepting the prosecutor's version of the eye rolling incident. It noted that the prosecutor's credibility had been previously undermined by other erroneous statements. For example, the prosecutor said that Juror 19, another prospective African-American juror, was too youthful despite the fact that she was a grandmother and attempted to use gender as a basis for exclusion. On this basis, the court overturned Collins' conviction.
The U.S. Supreme Court granted a writ of certiorari
.
. The Court unanimously reversed and remanded, stating "Reasonable minds reviewing the record might disagree about the prosecutor's credibility, but on habeas review that does not suffice to supersede the trial court's credibility determination."
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...
(2006), was 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...
regarding a prosecutor
Prosecutor
The prosecutor is the chief legal representative of the prosecution in countries with either the common law adversarial system, or the civil law inquisitorial system...
's use of a peremptory challenge
Peremptory challenge
Peremptory challenge usually refers to a right in jury selection for the defense and prosecution to reject a certain number of potential jurors who appear to have an unfavorable bias without having to give any reason...
to remove a young African American
African American
African Americans are citizens or residents of the United States who have at least partial ancestry from any of the native populations of Sub-Saharan Africa and are the direct descendants of enslaved Africans within the boundaries of the present United States...
woman, Juror 16, from a defendant's drug trial jury
Jury
A jury is a sworn body of people convened to render an impartial verdict officially submitted to them by a court, or to set a penalty or judgment. Modern juries tend to be found in courts to ascertain the guilt, or lack thereof, in a crime. In Anglophone jurisdictions, the verdict may be guilty,...
in a California
California
California is a state located on the West Coast of the United States. It is by far the most populous U.S. state, and the third-largest by land area...
court case, based on her youth and on her alleged "eye rolling" in answer to a question. The defendant, Steven Martell Collins, challenged the striking of Juror 16, saying her exclusion was based on race
Racism
Racism is the belief that inherent different traits in human racial groups justify discrimination. In the modern English language, the term "racism" is used predominantly as a pejorative epithet. It is applied especially to the practice or advocacy of racial discrimination of a pernicious nature...
, but the trial judge
Judge
A judge is a person who presides over court proceedings, either alone or as part of a panel of judges. The powers, functions, method of appointment, discipline, and training of judges vary widely across different jurisdictions. The judge is supposed to conduct the trial impartially and in an open...
agreed that the prosecutor's reasons were race-neutral. The California Court of Appeal upheld the trial court's ruling, and the Federal District Court
United States District Court for the Central District of California
The United States District Court for the Central District of California serves over 18 million people in southern and central California, making it the largest federal judicial district by population...
dismissed Collins' habeas corpus
Habeas corpus
is a writ, or legal action, through which a prisoner can be released from unlawful detention. The remedy can be sought by the prisoner or by another person coming to his aid. Habeas corpus originated in the English legal system, but it is now available in many nations...
petition with prejudice. However, the Ninth Circuit Court of Appeals
United States Court of Appeals for the Ninth Circuit
The United States Court of Appeals for the Ninth Circuit is a U.S. federal court with appellate jurisdiction over the district courts in the following districts:* District of Alaska* District of Arizona...
reversed and remanded, stating that the dismissal was unreasonable based, among other reasons, on the lack of evidence
Evidence
Evidence in its broadest sense includes everything that is used to determine or demonstrate the truth of an assertion. Giving or procuring evidence is the process of using those things that are either presumed to be true, or were themselves proven via evidence, to demonstrate an assertion's truth...
that the eye rolling had occurred.
History
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...
(1986) the Supreme Court ruled that a prosecutor cannot systematically use peremptory challenges to strike jurors based on race. The court set forth a three-step process in evaluating claims of discrimination. First, the defendant must present reasons that support the contention that the prosecutor's peremptory challenges were based on race. Second, the State must produce race-neutral explanations for the peremptory challenge. Third, the trial court must determine if the peremptory challenges were based on race or on other factors. In Georgia v. McCollum
Georgia v. McCollum
Georgia v. McCollum, 505 U.S. 42 , was a case in which the Supreme Court of the United States held that a criminal defendant cannot make peremptory challenges based solely on race. The court had previously held in Batson v. Kentucky that prosecutors cannot make peremptory challenges based on race,...
(1992) the Court ruled that the three-step procedure applied equally to the defense, and in J.E.B. v. Alabama ex rel. T.B.
J.E.B. v. Alabama ex rel. T.B.
J. E. B. v. Alabama ex rel. T. B., 511 U.S. 127 , was a case in which the Supreme Court of the United States held that making peremptory challenges based solely on a prospective juror's sex is unconstitutional. J.E.B. extended the court's existing precedent in Batson v...
(1994) to challenges based on gender. However the Court has always held, inter alia
Inter Alia
-Track listing:# Inter Alia# Outfox'd # Righteous Badass # The Altogether feat. Bix, Apt, UNIVERSE ARM and Cal# The Day-to-Daily# Trouble Brewing # The Prestidigitator# The Force...
, the ultimate burden of proving or disproving racial motivation for the strike always falls on the party challenging the strike.
Facts of the case
Steven Martell Collins, an African American male, was on trial in the superior courtSuperior court
In common law systems, a superior court is a court of general competence which typically has unlimited jurisdiction with regard to civil and criminal legal cases...
of Los Angeles County, California
Los Angeles County, California
Los Angeles County is a county in the U.S. state of California. As of 2010 U.S. Census, the county had a population of 9,818,605, making it the most populous county in the United States. Los Angeles County alone is more populous than 42 individual U.S. states...
for possession of drugs with intent to distribute. Because he was a habitual criminal, he was eligible for California's Three Strikes sentencing law
Three strikes law
Three strikes laws)"are statutes enacted by state governments in the United States which require the state courts to hand down a mandatory and extended period of incarceration to persons who have been convicted of a serious criminal offense on three or more separate occasions. These statutes became...
. During jury selection
Jury selection
Jury selection are many methods used to choose the people who will serve on a trial jury. The jury pool is first selected from among the community using a reasonably random method. The prospective jurors are then questioned in court by the judge and/or attorneys...
, the prosecutor
Prosecutor
The prosecutor is the chief legal representative of the prosecution in countries with either the common law adversarial system, or the civil law inquisitorial system...
removed an African American woman, Juror 16, on a peremptory challenge. When Collins contended that the juror was removed because of her race, the prosecutor listed race-neutral reasons for the challenge. These reasons included that the juror had "rolled her eyes" in response to a question, that because of her youth she may be tolerant of drugs, and that she lacked sufficient ties to the community. The trial court stated that it did not see the rolling of the eyes by Juror 16 but agreed that she was youthful, and while noting that a white male juror was also dismissed for being youthful, ruled it would give the prosecutor "the benefit of the doubt" and allow the juror strike to stand. Collins was convicted and received a 25-year sentence
Sentence (law)
In law, a sentence forms the final explicit act of a judge-ruled process, and also the symbolic principal act connected to his function. The sentence can generally involve a decree of imprisonment, a fine and/or other punishments against a defendant convicted of a crime...
.
Appeals
Collins appealed his case to the California Courts of Appeal claiming his rights had been violated by the trial judge in allowing jury discrimination. The Court of Appeal rejected this claim, using the precedent giving greater deference to the trial court's finding regarding claims of racial bias. After the California Supreme Court denied review, Collins filed a petition for habeas corpusHabeas corpus in the United States
Habeas corpus , Latin for "you [shall] have the body," is the name of a legal action or writ by means of which detainees can seek relief from unlawful imprisonment...
in the Federal District Court. The District Court conducted a full review and found the claim was without merit.
The Ninth Circuit Court of Appeals
United States Court of Appeals for the Ninth Circuit
The United States Court of Appeals for the Ninth Circuit is a U.S. federal court with appellate jurisdiction over the district courts in the following districts:* District of Alaska* District of Arizona...
reviewed the evidence and concluded that, since the trial court had not witnessed Juror 16's alleged "eye rolling", that the trial judge erred in accepting the prosecutor's version of the eye rolling incident. It noted that the prosecutor's credibility had been previously undermined by other erroneous statements. For example, the prosecutor said that Juror 19, another prospective African-American juror, was too youthful despite the fact that she was a grandmother and attempted to use gender as a basis for exclusion. On this basis, the court overturned Collins' conviction.
The U.S. Supreme Court granted a writ of certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
.
Finding
The Supreme Court held that the Ninth Circuit's "attempt to use a set of debatable inferences to set aside the conclusion" fails to satisfy the Antiterrorism and Effective Death Penalty Act of 1996Antiterrorism and Effective Death Penalty Act of 1996
The Antiterrorism and Effective Death Penalty Act of 1996, Pub. L. No. 104-132, 110 Stat. 1214, is an act of Congress signed into law on April 24, 1996...
. The Court unanimously reversed and remanded, stating "Reasonable minds reviewing the record might disagree about the prosecutor's credibility, but on habeas review that does not suffice to supersede the trial court's credibility determination."
See also
- Capital Jury ProjectCapital Jury ProjectThe Capital Jury Project is a consortium of university-based research studies on the decision-making of jurors in death penalty cases in the United States. It was founded in 1991 and is supported by the National Science Foundation...
- List of United States Supreme Court cases, volume 546
- List of United States Supreme Court cases
External links
- Full text opinion from Justia.com
- CJLF: Supreme Court is going to rule on Ninth Circuit Racial Bias Ruling (interest group press release on the case)