Madison: No Batson Violation for Alabama Death Row Inmate

In Madison v. Comm., Ala. Dept. of Corrections, No. 13-12348 (Aug. 4, 2014), the Court affirmed the denial of habeas relief to an Alabama death row inmate sentenced to death for a 1985 murder, rejecting the claim of a Batson violation during jury selection. The Court reviewed deferentially the findings of the district court, after an evidentiary hearing, regarding the Batson findings. The Court noted that Madison had put forward a “strong” prima facie case of purposeful discrimination against black jurors. Nonetheless, the Court deferred to the district court’s findings that the reasons for striking black prospective jurors were race-neutral.