Briggs v. Grounds

Summarized by:

  • Court: 9th Circuit Court of Appeals Archives
  • Area(s) of Law: Civil Procedure
  • Date Filed: 06-15-2012
  • Case #: 10-16683
  • Judge(s)/Court Below: Circuit Judge Tallman for the Court; Circuit Judge Graber; Circuit Judge Berzon dissenting.
  • Full Text Opinion

The prosecution's use of preemptory challenges to strike three African American prospective jurors was explained by race-neutral reasoning. As such, the denial of Brigg's habeas petition was properly denied by the trial court and California Court of Appeals.

Averill Briggs was convicted of lewd acts against a child and burglary. His habeas petition regarding preemptory challenges of three African-American prospective jurors was denied by the trial court and California Court of Appeals. The question before this Court is whether the prosecution’s race neutral reason for three peremptory challenges should be believed, as required by the Batson three step test. The Court made this determination by looking at the totality of the relevant facts. The standard is to defer to the state court, unless the court was “objectively unreasonable” in its decision. This Court also finds that the trial court is in the best position to evaluate the facts relating to this matter, as it was in possession of the juror questionnaires. Briggs focused primarily on the jurors’ questionnaires without giving much consideration to the jurors’ answer to the voir dire questions. The Court looked at the comparison of the answers from the excused jurors with those from the seated jurors. One of the excused jurors, Lawrence L., had been accused of sexual harassment and claimed this would impact his decision in the case. Georgia M. was removed because she did indicated that she would hold the prosecution to a higher standard than required by law and because she did not understand certain legal principles explained to her. Sam R. was excused because he was flippant during voir dire, claimed he would have a bias without further describing what this would be, and believed that teenagers were susceptible to coaching. Because the Court does not find the Court of Appeals’ decision to be “objectively unreasonable, it affirms the decision of the Court of Appeals and trial court. AFFIRMED.

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