Miller-El v. Dretke

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2005 United States Supreme Court case

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

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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

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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

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↑ Miller-El v. Dretke, 545 U.S. 231 (2005).
↑ Miller-El, 545 U.S. at 240.
↑ Miller-El, 545 U.S. at 240-41.
↑ Miller-El, 545 U.S. at 241.
↑ Miller-El, 545 U.S. at 255.
↑ Miller-El, 545 U.S. at 263.
↑ "Former death row inmate pleads guilty to 1985 crime" . The Dallas Morning News. Plainview Herald.