Snyder v. Louisiana

CourtUnited States Supreme Court
Citation552 U.S. 472,76 USLW 4136,170 L.Ed.2d 175,08 Cal. Daily Op. Serv. 3043,2008 Daily Journal D.A.R. 3757,128 S.Ct. 1203
Docket NumberNo. 06–10119.,06–10119.
PartiesAllen SNYDER, Petitioner, v. LOUISIANA
Decision Date19 March 2008

08 Cal. Daily Op. Serv. 3043
128 S.Ct. 1203
170 L.Ed.2d 175
2008 Daily Journal D.A.R. 3757
552 U.S. 472
76 USLW 4136

Allen SNYDER, Petitioner,

No. 06–10119.

Supreme Court of the United States

Argued Dec. 4, 2007.Decided March 19, 2008.

[128 S.Ct. 1204]

[552 U.S. 472]

Syllabus *

During voir dire in petitioner's capital murder case, the prosecutor used peremptory strikes to eliminate black prospective jurors who had survived challenges for cause. The jury convicted petitioner and sentenced him to death. Both on direct appeal and on remand in light of Miller–El v. Dretke, 545 U.S. 231, 125 S.Ct. 2317, 162 L.Ed.2d 196, the Louisiana Supreme Court rejected petitioner's claim that the prosecution's peremptory strikes of certain prospective jurors, including Mr. Brooks, were based on race, in violation of Batson v. Kentucky, 476 U.S. 79, 106 S.Ct. 1712, 90 L.Ed.2d 69.

Held: The trial judge committed clear error in rejecting the Batson objection to the strike of Mr. Brooks. Pp. 1207 – 1212.

(a) Under Batson's three-step process for adjudicating claims such as petitioner's, (1) a defendant must make a prima facie showing that the challenge was based on race; (2) if so, “ ‘the prosecution must offer a race-neutral basis for striking the juror in question’ ”; and (3) “ ‘in light of the parties' submissions, the trial court must determine whether the defendant has shown purposeful discrimination.’ ” Miller–El, supra, at 277, 125 S.Ct. 2317 (THOMAS, J., dissenting) (quoting [128 S.Ct. 1205] Miller–El v. Cockrell, 537 U.S. 322, 328–329, 123 S.Ct. 1029, 154 L.Ed.2d 931). Unless it is clearly erroneous, the trial court's ruling must be sustained on appeal. The trial court's role is pivotal, for it must evaluate the demeanor of the prosecutor exercising the challenge and the juror being excluded. Pp. 1207 – 1208.

(b) While all of the circumstances bearing on the racial-animosity issue must be consulted in considering a Batson objection or reviewing a ruling claimed to be a Batson error, the explanation given for striking Mr. Brooks, a college senior attempting to fulfill his student-teaching obligation, is insufficient by itself and suffices for a Batson error determination. Pp. 1208 – 1212.

(1) It cannot be presumed that the trial court credited the prosecution's first race-neutral reason, that Mr. Brooks looked nervous. Deference is owed to a trial judge's finding that an attorney credibly relied on demeanor in exercising a strike, but here, the trial judge simply allowed the challenge without explanation. Since Mr. Brooks was not challenged until the day after he was questioned and thus after dozens of other jurors had been called, the judge might not have recalled his demeanor. Or he may have found such consideration unnecessary, instead

[552 U.S. 473]

basing his ruling on the second proffered reason for the strike. Pp. 1208 – 1209.

(2) That reason—Mr. Brooks' student-teaching obligation—fails even under the highly deferential standard of review applicable here. Mr. Brooks was 1 of more than 50 venire members expressing concern that jury service or sequestration would interfere with work, school, family, or other obligations. Although he was initially concerned about making up lost teaching time, he expressed no further concern once a law clerk reported that the school's dean would work with Mr. Brooks if he missed time for a trial that week, and the prosecutor did not question him more deeply about the matter. The proffered reason must be evaluated in light of the circumstances that the colloquy and law clerk report took place on Tuesday, the prosecution struck Mr. Brooks on Wednesday, the trial's guilt phase ended on Thursday, and its penalty phase ended on Friday. The prosecutor's scenario—that Mr. Brooks would have been inclined to find petitioner guilty of a lesser included offense to obviate the need for a penalty phase—is both highly speculative and unlikely. Mr. Brooks would be in a position to shorten the trial only if most or all of the jurors had favored a lesser verdict. Perhaps most telling, the trial's brevity, which the prosecutor anticipated on the record during voir dire, meant that jury service would not have seriously interfered with Mr. Brooks' ability to complete his student teaching. The dean offered to work with him, and the trial occurred relatively early in the fall term, giving Mr. Brooks several weeks to make up the time. The implausibility of the prosecutor's explanation is reinforced by his acceptance of white jurors who disclosed conflicting obligations that appear to have been at least as serious as Mr. Brooks'. Under Batson's third stage, the prosecution's pretextual explanation gives rise to an inference of discriminatory intent. There is no need to decide here whether, in Batson cases, once a discriminatory intent is shown to be a motivating factor, the burden shifts to the prosecution to show that the discriminatory factor was not determinative. It is enough to recognize that a peremptory strike shown to have been motivated in substantial part by discriminatory intent could not be sustained based on any lesser showing by the prosecution. The record here does not show that the prosecution would have pre-emptively challenged Mr. Brooks based on his nervousness alone, [128 S.Ct. 1206] and there is no realistic possibility that the subtle question of causation could be profitably explored further on remand more than a decade after petitioner's trial. Pp. 1208 – 1212.

942 So.2d 484, reversed and remanded.

ALITO, J., delivered the opinion of the Court, in which ROBERTS, C. J., and STEVENS, KENNEDY, SOUTER, GINSBURG, and BREYER, JJ., joined. THOMAS, J., filed a dissenting opinion, in which SCALIA, J., joined.

Stephen B. Bright, Counsel of Record, Southern Center for Human Rights, Atlanta, Georgia, Jelpi P. Picou, Jr., Marcia Widder, Capital Appeals Project, New Orleans, Louisiana, for Petitioner.

Paul D. Connick, Jr., District Attorney, Jefferson Parish, State of Louisiana, Terry M. Boudreaux, Counsel of Record, Assistant District Attorney, Gretna, Louisiana, for Respondent.

Justice ALITO delivered the opinion of the Court.

[552 U.S. 474]

Petitioner Allen Snyder was convicted of first-degree murder in a Louisiana court and was sentenced to death. He asks us to review a decision of the Louisiana Supreme Court rejecting his claim that the prosecution exercised some of its peremptory jury challenges based on race, in violation of Batson v. Kentucky, 476 U.S. 79, 106 S.Ct. 1712, 90 L.Ed.2d 69 (1986). We hold that the trial court committed clear error in its ruling on a Batson objection, and we therefore reverse.


The crime for which petitioner was convicted occurred in August 1995. At that time, petitioner and his wife, Mary, had separated. On August 15, they discussed the possibility of reconciliation, and Mary agreed to meet with petitioner the next day. That night, Mary went on a date with Howard Wilson. During the evening, petitioner repeatedly attempted to page Mary, but she did not respond. At approximately 1:30 a.m. on August 16, Wilson drove up to the home of Mary's mother to drop Mary off. Petitioner was waiting at the scene armed with a knife. He opened the driver's side door of Wilson's car and repeatedly stabbed the occupants,

[552 U.S. 475]

killing Wilson and wounding Mary.

The State charged petitioner with first-degree murder and sought the death penalty based on the aggravating circumstance that petitioner had knowingly created a risk of death or great bodily harm to more than one person. See La.Code Crim. Proc. Ann., Art. 905.4(A)(4) (West Supp.2008).

Voir dire began on Tuesday, August 27, 1996, and proceeded as follows. During the first phase, the trial court screened the panel to identify jurors who did not meet Louisiana's requirements for jury service or claimed that service on the jury or sequestration for the duration of the trial would result in extreme hardship. More than 50 prospective jurors reported that they had work, family, or other commitments that would interfere with jury service. In each of those instances, the nature of the conflicting commitments was explored, and some of these jurors were dismissed. App. 58–164.

In the next phase, the court randomly selected panels of 13 potential jurors for [128 S.Ct. 1207] further questioning. Id., at 166–167. The defense and prosecution addressed each panel and questioned the jurors both as a group and individually. At the conclusion of this questioning, the court ruled on challenges for cause. Then, the prosecution and the defense were given the opportunity to use peremptory challenges (each side had 12) to remove remaining jurors. The court continued this process of calling 13–person panels until the jury was filled. In accordance with Louisiana law, the parties were permitted to exercise “backstrikes.” That is, they were allowed to use their peremptories up until the time when the final jury was sworn and thus were permitted to strike jurors whom they had initially accepted when the jurors' panels were called. See La.Code Crim. Proc. Ann., Art. 795 (B)(1) (West 1998); State v. Taylor, 93–2201, pp. 22–23 (La.2/28/96), 669 So.2d 364, 376.

Eighty-five prospective jurors were questioned as members of a panel. Thirty-six of these survived challenges for

[552 U.S. 476]

cause; 5 of the 36 were black; and all 5 of the prospective black jurors were eliminated by the prosecution through the use of peremptory strikes. The jury found petitioner guilty of first-degree murder and determined that he should receive the death penalty.

On direct appeal, the Louisiana Supreme Court conditionally affirmed petitioner's conviction. The court rejected petitioner's Batson claim but remanded the case for a nunc pro tunc determination of petitioner's competency to stand trial. State v. Snyder, 98–1078 (La.4/14/99), 750 So.2d 832. Two justices dissented and would have found a Batson violation. See id., at 866 (Johnson, J.,...

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