Johnson v. Williams
January 17, 2012
Case #: 11-465
646 F.3d 626 (9th Cir. 2011)
Full Text Opinion: http://www.ca9.uscourts.gov/datastore/opinions/2011/05/23/07-56127.pdf
Habeas Corpus: (1)Whether a habeas petitioner's claim has been “adjudicated on the merits” for purposes of 28 U.S.C. § 2254(d); and (2) whether, under § 2254, a federal habeas court (a) may grant relief on the ground that the petitioner had a Sixth Amendment right to retain a biased juror on the panel and (b) may reject a state court’s finding of juror bias because it disagrees with the finding and the reasons stated for it, even where the finding was rationally supported by evidence in the state-court record.
After exhausting her direct appeals following a conviction for murder, Petitioner Tara Williams filed a state habeas corpus action in California state court. Among several claims, Petitioner asserted that the trial court impermissibly excluded a juror during deliberations, when other members of the jury expressed concern, by writing a note to the court, that a particular juror needed “a higher standard of proof” for a First Degree Murder charge. After questioning the particular juror outside the presence of the other jurors, the trial court, on a finding that the particular juror refused to properly apply the law because he was “biased,” removed the juror from deliberations. Subsequently, the jury returned a guilty verdict and Petitioner was sentenced to life in prison.
The Los Angeles County Superior Court found that Petitioner’s “jury issue” is a matter for direct review, as opposed to state habeas, and dismissed the claim. Subsequent appeals to the California Court of Appeal and Supreme Court of California were dismissed because the issue was “raised and rejected” on appeal and thus could not be raised again in a write petition. Taking her case to federal court by filing a federal habeas cause of action, the local magistrate, citing the highly deferential standard federal courts give to state habeas corpus decisions, recommended to dismiss Petitioner’s claims with prejudice, and the district court adopted those recommendations. Petitioner appealed to the Ninth Circuit Court of Appeals where the court reversed the district court’s decision to dismiss with prejudice on the grounds that the lower court “did not consider whether removal of the known holdout juror violated the Sixth Amendment.”
The Supreme Court granted cert in this case as it presents a broad new challenge by the state of California to the Ninth Circuit Court, arguing that it has overstepped the limits on a federal appeals court’s authority to second-guess a state court criminal decision. Additionally, this case also involves a major issue under the Sixth Amendment as to whether it violates a person’s right to a jury trial for a judge to dismiss a juror after deliberations have commenced when a jury appears to be deadlocked, if the dismissal was due in part to that juror’s view on how the verdict should go.