Snyder v. Louisiana
Encyclopedia
Snyder v. Louisiana, 552 U.S. 472 (2008), was a United States Supreme Court
case about racial issues in jury selection
in death penalty
cases. Justice Samuel Alito
, writing for the 7–2 majority, ruled that the prosecutor's use of peremptory strikes to remove African American
jurors violated the Court's earlier holding in Batson v. Kentucky
. Justice Clarence Thomas
dissented.
in the August 1995 stabbing death of Howard Wilson. The State of Louisiana sought the death penalty
. Voir dire
for the jury
began on August 27, 1996. In accordance with Louisiana law, the parties were permitted to use their peremptory strikes up until the time when the final jury was sworn and thus were permitted to strike jurors whom they had initially accepted when the jurors’ panels were called. Eighty-five prospective jurors were questioned as members of a panel. Thirty-six of these potential jurors survived challenges for cause; five of the thirty-six were African American
; and all five of the prospective black jurors were eliminated by the prosecution through the use of peremptory strikes. The jury found petitioner guilty and determined that he should receive the death penalty.
, the prosecution should not have been permitted to exercise its peremptory jury challenges based on race. The Louisiana Supreme Court
conditionally affirmed petitioner’s conviction, rejecting petitioner’s Batson claim, but remanded the case for a nunc pro tunc
determination of petitioner’s competency to stand trial. On remand, the trial court found that petitioner had been competent to stand trial, and the Louisiana Supreme Court affirmed that determination.
Snyder then petitioned the Supreme Court of the United States
for a writ of certiorari
. While Snyder's petition was pending, the U.S. Supreme Court decided Miller-El v. Dretke
; as a result, they granted Snyder's petition, vacated the judgment, and remanded the case to the Louisiana Supreme Court for further consideration in light of Miller-El. On remand, the Louisiana Supreme Court again rejected Snyder’s Batson claim, this time by a vote of 4 to 3. The U.S. Supreme Court again granted certiorari.
?
, writing for the Court, concluded that the trial judge had acted improperly in allowing the prosecutor to peremptorily strike the African American jurors. Alito noted that the reasons given by the prosecution for striking the jurors applied equally well to the white jurors the prosecution did not strike.
dissented from the opinion of the Court. Thomas wrote that the court improperly second-guessed the fact-based decisions of the trial court, and that a higher standard of deference ought to have been applied.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case about racial issues in jury selection
Jury selection
Jury selection are many methods used to choose the people who will serve on a trial jury. The jury pool is first selected from among the community using a reasonably random method. The prospective jurors are then questioned in court by the judge and/or attorneys...
in death penalty
Capital punishment in the United States
Capital punishment in the United States, in practice, applies only for aggravated murder and more rarely for felony murder. Capital punishment was a penalty at common law, for many felonies, and was enforced in all of the American colonies prior to the Declaration of Independence...
cases. Justice Samuel Alito
Samuel Alito
Samuel Anthony Alito, Jr. is an Associate Justice of the U.S. Supreme Court. He was nominated by President George W. Bush and has served on the court since January 31, 2006....
, writing for the 7–2 majority, ruled that the prosecutor's use of peremptory strikes to remove African American
African American
African Americans are citizens or residents of the United States who have at least partial ancestry from any of the native populations of Sub-Saharan Africa and are the direct descendants of enslaved Africans within the boundaries of the present United States...
jurors violated the Court's earlier holding in Batson v. Kentucky
Batson v. Kentucky
Batson v. Kentucky, , was a case in which the United States Supreme Court ruled that a prosecutor's use of peremptory challenge—the dismissal of jurors without stating a valid cause for doing so—may not be used to exclude jurors based solely on their race...
. Justice Clarence Thomas
Clarence Thomas
Clarence Thomas is an Associate Justice of the Supreme Court of the United States. Succeeding Thurgood Marshall, Thomas is the second African American to serve on the Court....
dissented.
Overview
The petitioner, Allen Snyder, was charged with first-degree murderMurder
Murder is the unlawful killing, with malice aforethought, of another human being, and generally this state of mind distinguishes murder from other forms of unlawful homicide...
in the August 1995 stabbing death of Howard Wilson. The State of Louisiana sought the death penalty
Capital punishment
Capital punishment, the death penalty, or execution is the sentence of death upon a person by the state as a punishment for an offence. Crimes that can result in a death penalty are known as capital crimes or capital offences. The term capital originates from the Latin capitalis, literally...
. Voir dire
Voir dire
Voir dire is a phrase in law which comes from the Anglo-Norman language. In origin it refers to an oath to tell the truth , i.e., to say what is true, what is objectively accurate or subjectively honest, or both....
for the jury
Jury
A jury is a sworn body of people convened to render an impartial verdict officially submitted to them by a court, or to set a penalty or judgment. Modern juries tend to be found in courts to ascertain the guilt, or lack thereof, in a crime. In Anglophone jurisdictions, the verdict may be guilty,...
began on August 27, 1996. In accordance with Louisiana law, the parties were permitted to use their peremptory strikes up until the time when the final jury was sworn and thus were permitted to strike jurors whom they had initially accepted when the jurors’ panels were called. Eighty-five prospective jurors were questioned as members of a panel. Thirty-six of these potential jurors survived challenges for cause; five of the thirty-six were African American
African American
African Americans are citizens or residents of the United States who have at least partial ancestry from any of the native populations of Sub-Saharan Africa and are the direct descendants of enslaved Africans within the boundaries of the present United States...
; and all five of the prospective black jurors were eliminated by the prosecution through the use of peremptory strikes. The jury found petitioner guilty and determined that he should receive the death penalty.
Procedural history
Snyder appealed his conviction, arguing that under Batson v. KentuckyBatson v. Kentucky
Batson v. Kentucky, , was a case in which the United States Supreme Court ruled that a prosecutor's use of peremptory challenge—the dismissal of jurors without stating a valid cause for doing so—may not be used to exclude jurors based solely on their race...
, the prosecution should not have been permitted to exercise its peremptory jury challenges based on race. The Louisiana Supreme Court
Louisiana Supreme Court
The Supreme Court of Louisiana is the highest court and court of last resort in the U.S. state of Louisiana. The modern Supreme Court, composed of seven justices, meets in the French Quarter of New Orleans....
conditionally affirmed petitioner’s conviction, rejecting petitioner’s Batson claim, but remanded the case for a nunc pro tunc
Nunc pro tunc
Nunc pro tunc is a Latin expression in common legal use in the English language. It means Now for then. In general, a court ruling "nunc pro tunc" applies retroactively to correct an earlier ruling.-Definition:...
determination of petitioner’s competency to stand trial. On remand, the trial court found that petitioner had been competent to stand trial, and the Louisiana Supreme Court affirmed that determination.
Snyder then petitioned the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
for a writ of certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
. While Snyder's petition was pending, the U.S. Supreme Court decided Miller-El v. Dretke
Miller-El v. Dretke
Miller-El v. Dretke, 545 U.S. 231 , is a decision by the Supreme Court of the United States that clarified the constitutional limitations on the use by prosecutors of peremptory challenges and of the Texas procedure appropriately termed the "jury shuffle."-Factual background:Thomas Miller-El was...
; as a result, they granted Snyder's petition, vacated the judgment, and remanded the case to the Louisiana Supreme Court for further consideration in light of Miller-El. On remand, the Louisiana Supreme Court again rejected Snyder’s Batson claim, this time by a vote of 4 to 3. The U.S. Supreme Court again granted certiorari.
Issue
Did the state's dismissal by peremptory challenge of all of the African American potential jurors amount to a violation of the Equal Protection ClauseEqual Protection Clause
The Equal Protection Clause, part of the Fourteenth Amendment to the United States Constitution, provides that "no state shall ... deny to any person within its jurisdiction the equal protection of the laws"...
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Parties' arguments
Petitioner claimed that at least two of the African American jurors were struck from the jury for purely race-based reasons. Respondent claimed that the race-neutral reasons offered at voir dire were legitimate, and the trial court agreed. Petitioner argued that the trial court should have applied closer scrutiny to the respondent's reasoning.Opinion of the Court
Justice Samuel AlitoSamuel Alito
Samuel Anthony Alito, Jr. is an Associate Justice of the U.S. Supreme Court. He was nominated by President George W. Bush and has served on the court since January 31, 2006....
, writing for the Court, concluded that the trial judge had acted improperly in allowing the prosecutor to peremptorily strike the African American jurors. Alito noted that the reasons given by the prosecution for striking the jurors applied equally well to the white jurors the prosecution did not strike.
Dissent
Justice Clarence ThomasClarence Thomas
Clarence Thomas is an Associate Justice of the Supreme Court of the United States. Succeeding Thurgood Marshall, Thomas is the second African American to serve on the Court....
dissented from the opinion of the Court. Thomas wrote that the court improperly second-guessed the fact-based decisions of the trial court, and that a higher standard of deference ought to have been applied.
External links
- Snyder v. Louisiana at supremecourt.gov (docket information)
- full text (HTML with links to precedent, statutes, and U.S. Constitution)