Michael Rivera v. Illinois (556 U.S. 148)

U.S. Supreme Court · decided March 31, 2009 · Supreme Court Database (Spaeth)

Citation
556 U.S. 148 · 129 S. Ct. 1446
Decided
March 31, 2009
Term
October Term 2008
Vote
9–0
Majority author
Justice Ginsburg
Issue area
Criminal Procedure
Disposition
Affirmed
Outcome
Petitioning party lost
Ideological direction
Conservative

Opinion excerpt

Justice Ginsburg delivered the opinion of the Court. This case concerns the consequences of a state trial court’s erroneous denial of a defendant’s peremptory challenge to the seating of a juror in a criminal case. If all seated jurors are qualified and unbiased, does the Due Process Clause of the Fourteenth Amendment nonetheless require automatic reversal of the defendant’s conviction? Following a jury trial in an Illinois state court, defendant-petitioner Michael Rivera was convicted of first-degree murder and sentenced to a prison term of 85 years. On appeal, Rivera challenged the trial court’s rejection of his peremptory challenge to venire member Deloris Gomez. Gomez sat on Rivera’s jury and indeed served as the jury’s foreperson. It is conceded that there was no basis to challenge Gomez for cause. She met the requirements for jury service, and Rivera does not contend that she was in fact biased against him. The Supreme Court of Illinois held that the peremptory challenge should have been allowed, but further held that the error was harmless and therefore did not warrant reversal of Rivera’s conviction. We affirm the judgment of the Illinois Supreme Court. The right to exercise peremptory challenges in state court is determined by state law. This Court has “long recognized” that “peremptory challenges are not of federal constitutional dimension.” United States v.…

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