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.
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 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]
