Tuesday, November 5, 2013

Miller-El v. Dretke case brief

Miller-El v. Dretke case brief summary
545 U.S. 231 (2005)

Petitioner, an African-American prison inmate, was convicted in state court of murder and sentenced to death, but the inmate asserted that the prosecution used peremptory challenges to exclude black jurors on the basis of race. Upon the grant of a writ of certiorari, the inmate appealed the judgment of the U.S. Court of Appeals for the Fifth Circuit which upheld the denial of the inmate's petition for a federal writ of habeas corpus.

Ten of 11 black venire panelists were peremptorily struck by the prosecution, however, the prosecution contended that the strikes were based on the jurors' ambivalence or opposition to the death penalty.

  • The U.S. Supreme Court held, however, that the cumulative evidence of prosecution tactics clearly raised the inference that the strikes were discriminatory. 
  • Happenstance was unlikely to produce the disparity shown by the substantial percentage of black jurors who were struck, especially where white jurors with comparable views were not challenged. 
  • Further, the prosecution took advantage of the state practice of allowing the shuffling of the names of prospective jurors to delay, in hopes of eliminating, black jurors from consideration. 
  • Also, prior to asking about death penalty views, most white panel members were given a bland description of the death penalty, while black members were given a graphic description to induce an aversion to the death penalty. 
  • Moreover, as a tactic to create cause to strike, blacks were not told the minimum penalty prior to providing their opinions of a proper minimum, and the prosecution office historically had a policy of excluding blacks from juries.


The judgment upholding the denial of the inmate's habeas corpus petition was reversed, and the case was remanded for entry of judgment in favor of the inmate and orders of appropriate relief.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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