Davis v. Ayala (576 U.S. 257)
U.S. Supreme Court · decided June 18, 2015 · Supreme Court Database (Spaeth)
- Citation
- 576 U.S. 257 · 135 S. Ct. 2187
- Decided
- June 18, 2015
- Term
- October Term 2014
- Vote
- 5–4
- Majority author
- Justice Alito
- Issue area
- Criminal Procedure
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Justice ALITOdelivered the opinion of the Court. A quarter-century after a California jury convicted Hector Ayala of triple murder and sentenced him to death, the Court of Appeals for the Ninth Circuit granted Ayala's application for a writ of habeas corpus and ordered the State to retry or release him. The Ninth Circuit's decision was based on the procedure used by the trial judge in ruling on Ayala's objections under Batson v. Kentucky,476 U.S. 79, 106 S.Ct. 1712, 90 L.Ed.2d 69 (1986), to some of the prosecution's peremptory challenges of prospective jurors. The trial judge allowed the prosecutor to explain the basis for those strikes outside the presence of the defense so as not to disclose trial strategy. On direct appeal, the California Supreme Court found that if this procedure violated any federal constitutional right, the error was harmless beyond a reasonable doubt. The Ninth Circuit, however, held that the error was harmful. The Ninth Circuit's decision was based on the misapplication of basic rules regarding harmless error. Assuming without deciding that a federal constitutional error occurred, the error was harmless under Brecht v. Abrahamson,507 U.S. 619, 113 S.Ct. 1710, 123 L.Ed.2d 353 (1993), and the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. § 2254(d). I A Ayala's conviction resulted from the attempted robbery of an automobile…
Excerpt of a 54,253-character opinion. The full text and citation network load in the interactive viewer above.