''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 turn on question ...

case that clarified the

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

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 (; often ; from an Anglo-Norman term in common law meaning "to speak the truth") is a legal term for procedures during a trial that help a judge decide certain issues: * Prospective jurors are questioned to decide whether they can be fair and i ...

'', 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 List of landmark court decisions in the United States, landmark decision of the United States Supreme Court ruling that a prosecutor's use of a peremptory challenge in a criminal case—the di ...

'' 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. In 2008, Miller-El pleaded guilty to the 1985 murder of Douglas Walker, a

Holiday Inn Holiday Inn by IHG is a chain of hotels based in Atlanta, Georgia and a brand of IHG Hotels & Resorts. The chain was founded in 1952 by Kemmons Wilson (1913–2003), who opened the first location in Memphis, Tennessee. The chain was a division ...

clerk who had been bound, gagged, then shot to death. The murder of Walker was the crime that Miller-El was originally sent to death row for. 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