Foster v. Chatman

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Constitutional Law
  • Date Filed: May 23, 2016
  • Case #: 14–8349
  • Judge(s)/Court Below: ROBERTS, C. J., delivered the opinion of the Court, in which KENNEDY, GINSBURG, BREYER, SOTOMAYOR, and KAGAN, JJ., joined. ALITO, J., filed an opinion concurring in the judgment. THOMAS, J., filed a dissenting opinion.
  • Full Text Opinion

The Constitution prohibits exercising preemptory strikes during voir dire used to remove potential jurors for discriminatory purposes and the three part Batson test is used to determine whether a strike was discriminatory.

Petitioner was convicted and sentenced to death for capital murder in Georgia state court. After voir dire, Petitioner entered a challenge based on Batson v. Kentucky, 476 U.S. 79 (1986), that the state had racially discriminated by using preemptory strikes to remove black jurors from the jury pool. The trial court denied the objection and Petitioner was found guilty and sentenced. Petitioner again challenged the preemptory strikes after trial, which were subsequently denied. On appeal, the Supreme Court of Georgia affirmed. Petitioner then sought a writ of habeas corpus, however; the Superior Court of Butts County, Georgia denied his writ because of the Georgia Supreme Court’s ruling and the doctrine of collateral estoppel that precluded Petitioner's writ for failing to show a sufficient change in the facts. The Supreme Court of Georgia also failed to issue Petitioner the “Certificate of Probable Cause” required for his appeal. On appeal to the Supreme Court, the Court first determined that jurisdiction was proper because the Court has jurisdiction to review decisions of lower courts to determine if a federal question was raised by the unreasoned decisions of a state's highest court. The Supreme Court ultimately held that the prosecution’s decision to strike the black jurors was substantially motivated by an intent to discriminate. Under the Batson analysis, the Court determined that (1) the prosecution had failed to provide any compelling, racially neutral, justifications for the preemptory strikes, and (2) the defendant had proved purposeful discrimination. The Court's decision was supported in part by the fact that some reasons given for disqualifying the black jurors would have also supported the striking of other white prospective jurors that actually served on the jury. REVERSED and REMANDED.

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