THALER v. HAYNES
Anthony Cardell Haynes was tried in a Texas state court for the murder of a police officer. The state sought the death penalty. During voir dire, two separate judges presided at different stages. One judge presided when the attorneys questioned the prospective jurors individually, the other judge presided when preemptory challenges were exercised. When the prosecutor struck an African-American juror, Mr. Thaler's attorney made a Batson objection -- arguing that the strike was racially motivated. The judge, who was not present during jury interviews, found that the strike was race neutral and denied the Batson objection. The case proceeded to trial and Mr. Haynes was convicted and sentenced to death.
On appeal, Mr. Haynes argued that "a trial judge who did not witness the actual voir dire cannot, as a matter of law, fairly evaluate a Batson challenge." The Texas Court of Criminal Appeals rejected the argument and affirmed the conviction. Mr. Haynes then filed for and was denied habeas corpus relief by a Texas federal district court. The U.S. Court of Appeals for the Fifth Circuit granted review. It held that the Texas Court of Criminal Appeals made an unreasonable application of U.S. Supreme Court precedent in its decision and Mr. Haynes warranted federal habeas corpus relief.
1) Does Batson v. Kentucky entitle a defendant to a new trial because the trial judge observed the prosecutor's explanation for the juror strike but did not observe the jury interviews?
2) Does Snyder v. Louisiana entitle a defendant to a new trial -- even when a prosecutor struck a prospective juror based on her friendly demeanor to defense counsel and not race -- because the trial judge observed the prosecutor's explanation for the strike but did not observe the jury interviews?
No and No. In a per curiam opinion, the Supreme Court reversed the Fifth Circuit and held that neither Batson nor Snyder require that a demeanor- based explanation must be rejected if the judge did not observe or cannot recall the juror's demeanor. The Court remanded the case to the Fifth Circuit for proceedings consistent with the opinion. Moreover, the Court instructed that the Fifth Circuit may consider whether the Texas Court of Criminal Appeals' determination may be overcome under the federal habeas statute's standard for reviewing a state court's resolution of questions of fact.