''Miller-El v. Dretke'', 545 U.S. 231 (2005), is a

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...

case that clarified the

constitutional A constitution is the aggregate of fundamental principles or established precedents that constitute the legal basis of a polity, organisation or other type of entity and commonly determine how that entity is to be governed. When these prin ...

limitations on the use by prosecutors of peremptory challenges and of the Texas procedure termed the "jury shuffle."

Background

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

In 1986, the Supreme Court ruled in ''

Batson v. Kentucky ''Batson v. Kentucky'', 476 U.S. 79 (1986), was a landmark decision of the United States Supreme Court ruling that a prosecutor's use of a peremptory challenge in a criminal case—the dismissal of jurors without stating a valid cause for doi ...

'' 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." Specifically, the Court allowed statistical analysis of the venire, side-by-side comparison of struck and empaneled jurors, disparate questioning, and evidence of historical discrimination.''Miller-El'', 545 U.S. at 263. The Court extended the holding of ''Miller-El'' in '' Snyder v. Louisiana''.

References

External links

* {{Equal protection and criminal procedure, jury, state=expanded Batson challenge case law United States Supreme Court cases United States Supreme Court cases of the Rehnquist Court 2005 in United States case law