Supreme Court of the United States
Ron Davis, Acting Warden, Petitioner v. Hector Ayala.
June 18, 2015135 S. Ct. 2187
Summary
The Supreme Court reversed the Ninth Circuit's grant of federal habeas relief to Hector Ayala, a California prisoner sentenced to death for a 1985 San Diego triple murder, whose counsel had been excluded from the ex parte portions of the Batson hearings at which the prosecution justified peremptory strikes against all seven available Black and Hispanic prospective jurors. Assuming without deciding that the exclusion violated federal constitutional rights, the Court held the error harmless under Brecht's actual-prejudice standard, which subsumes AEDPA §2254(d) because the California Supreme Court's ruling that any federal error was harmless beyond a reasonable doubt under Chapman was a merits adjudication with which fairminded jurists could agree. The Court found the record amply supported the prosecution's race-neutral reasons for each of the seven strikes and faulted the Ninth Circuit for de novo factual review and speculation about what counsel might have argued. Justice Kennedy filed a concurrence addressing Ayala's decades in solitary confinement; Justice Thomas concurred briefly in response; and Justice Sotomayor, joined by Justices Ginsburg, Breyer, and Kagan, dissented, arguing that grave doubt remained that counsel's exclusion substantially influenced the Batson outcomes.
Holding
- What harmless-error standard governs federal habeas review of a state court's merits determination that a constitutional error was harmless?. A habeas petitioner must satisfy Brecht's actual-prejudice standard, and because the state court's Chapman determination constitutes an adjudication of the claim on the merits, the Brecht test subsumes the limitations imposed by AEDPA §2254(d): relief cannot be granted unless the state court's rejection of the claim was contrary to or involved an unreasonable application of clearly established federal law, or was based on an unreasonable determination of the facts.
- Whether the assumed error was harmless as to the strike of Olanders D., an African-American prospective juror.. Any federal constitutional error was harmless with respect to Olanders D.: the record amply supports the prosecution's concerns about his unwillingness to impose the death penalty and the poor quality of his responses, and Ayala cannot establish that the ex parte hearing actually prejudiced him or that no fairminded jurist could agree with the state court's application of Chapman.
- Whether the assumed error was harmless as to the strike of Gerardo O., a Hispanic prospective juror.. Any federal constitutional error was harmless with respect to Gerardo O.: each proffered reason — limited English proficiency, suggested unwillingness to impose the death penalty, and failure to socialize with other jurors — was amply supported by the record, and Ayala cannot establish actual prejudice or that no fairminded jurist could agree with the state court's application of Chapman.
- Whether the assumed error was harmless as to the strike of Robert M. and the four remaining challenged prospective jurors (George S., Barbara S., Galileo S., and Luis M.).. Any federal constitutional error was harmless with respect to Robert M., George S., Barbara S., Galileo S., and Luis M.: Ayala does not come close to establishing actual prejudice under Brecht or that no fairminded jurist could agree with the California Supreme Court's determination that excluding counsel was harmless.
Docket 13–1428.