Supreme Court of the United States

Pitchford v. Cain

May 28, 2026225 L. Ed. 2d 11

Summary

Justice Kavanaugh's majority opinion held that the Mississippi Supreme Court unreasonably applied clearly established Batson precedents and unreasonably determined that Pitchford waived his opportunity to challenge the prosecutor's explanations for striking four black prospective jurors. The trial court stopped its inquiry after accepting facially race-neutral explanations, prevented defense counsel from pursuing rebuttal, and assured counsel that the objection was preserved. The Court reversed the Fifth Circuit and remanded without deciding whether the strikes were actually discriminatory. Justice Gorsuch dissented, joined by Justices Thomas, Alito, and Barrett. He maintained that Mississippi could require preservation of particular Batson arguments and that its waiver determination was at least reasonable under AEDPA.

Holding

  • Whether the trial court completed the required Batson inquiry.. The trial court erroneously omitted Batson's third step by denying defense counsel a sufficient opportunity to rebut the prosecutor's explanations and failing to determine whether those explanations were pretextual.
  • Whether the state court's waiver determination survived AEDPA review.. The Mississippi Supreme Court unreasonably applied clearly established Batson precedents and unreasonably determined that Pitchford waived his opportunity to rebut the prosecutor's explanations, satisfying §§2254(d)(1) and (2).

Docket 24-7351

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