Miller-El v. Dretke
| Miller-El v. Dretke | |||||
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| Argued December 6, 2004 Decided June 13, 2005 |
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| 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
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| 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. | |||||
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| Case opinions | |||||
| Majority | Souter, joined by Stevens, O'Connor, Kennedy, Ginsburg, Breyer | ||||
| Concurrence | Breyer | ||||
| Dissent | Thomas, joined by Rehnquist, Scalia | ||||
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 appropriately termed the "jury shuffle."
Background
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
In 1986, the US 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 US 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."[1] Specifically, the Court allowed statistical analysis of the venire,[2] side-by-side comparison of struck and empaneled jurors,[3] disparate questioning,[4] and evidence of historical discrimination.[5]
The Court extended the holding of Miller-El in Snyder v. Louisiana.
