Miller-El v. Dretke
| Miller-El v. Dretke | |
|---|---|
 | |
| Argued December 6, 2004 Decided June 13, 2005 | |
| Full case name | Miller-El v. Dretke, Director, Texas Department of Criminal Justice, Correctional Institutions Divisions |
| Citations | 545 U.S. 231 (more) 125 S. Ct. 2317; 162 L. Ed. 2d 196; 2005 U.S. LEXIS 4658; 73 U.S.L.W. 4479; 18 Fla. L. Weekly Fed. S 376 |
| Case history | |
| Prior | 361 F.3d 849 (5th Cir. 2004); cert. granted, 542 U.S. 936 (2004). |
| Holding | |
| The prosecution in the capital trial of Miller-El violated the Fourteenth Amendment as interpreted in Batson v. Kentucky when it racially discriminated against black potential jurors, and Miller-El is entitled to habeas corpus relief. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Souter, joined by Stevens, O'Connor, Kennedy, Ginsburg, Breyer |
| Concurrence | Breyer |
| Dissent | Thomas, joined by Rehnquist, Scalia |
| Laws applied | |
| U.S. Const. amend. XIV | |
Miller-El v. Dretke, 545 U.S. 231 (2005), is a United States Supreme Court case that clarified the constitutional limitations on the use by prosecutors of peremptory challenges and of the Texas procedure termed the "jury shuffle."[1]
Background
[edit]Thomas Miller-El was charged with capital murder committed in the course of a robbery. After voir dire, Miller-El moved to strike the entire jury because the prosecution had used its peremptory challenges to strike ten of the eleven African-Americans who were eligible to serve on the jury. This motion was denied, and Miller-El was subsequently found guilty and sentenced to death.
Opinion of the Court
[edit]In 1986, the Supreme Court ruled in Batson v. Kentucky that a prosecutor's use of peremptory challenges may not be used to exclude jurors on the basis of race. Miller-El appealed based on the Batson criteria and asked that his conviction be overturned. In June 2005, the Supreme Court ruled 6–3 to overturn Miller-El's death sentence, finding his jury selection process had been tainted by racial bias.
The Court had held in Batson that a defendant could rely on "all relevant circumstances" in making out a prima facie case of purposeful discrimination. Miller-El clarified that "all relevant circumstances" included evidence outside "the four corners of the case."[2] Specifically, the Court allowed statistical analysis of the venire,[3] side-by-side comparison of struck and empaneled jurors,[4] disparate questioning,[5] and evidence of historical discrimination.[6]
In 2008, Miller-El pleaded guilty to the 1985 murder of Douglas Walker, a Holiday Inn clerk who had been bound, gagged, then shot to death. The murder of Walker was the crime that Miller-El was originally sent to death row for.[7]
The Court extended the holding of Miller-El in Snyder v. Louisiana.
References
[edit]External links
[edit]- Text of Miller-El v. Dretke, 545 U.S. 231 (2005) is available from: Cornell CourtListener Google Scholar Justia Oyez (oral argument audio)