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Date: 05-31-2022

Case Style:

Leron Porter v. Patricia Anne Coyne-Fague

Case Number: 21-1333

Judge: Selyn

Court: United States Court of Appeals for the First Circuit on appeal from the District of Rhode Island (Providence County)

Plaintiff's Attorney:



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Defendant's Attorney: Christopher R. Bush, Assistant Attorney General

Description: Providence, Rhode Island civil rights lawyer represented Plaintiff, seeking a writ of habeas corpus.

No right is more fundamental to
our criminal justice system than the right of a defendant to a
fair trial. Over time, the Supreme Court has woven a tapestry of
rules designed to protect that right. An important strand in the
weave of that tapestry is laid out in Batson v. Kentucky, 476 U.S.
79 (1986), under which a defendant may challenge a prosecutor's
peremptory strike of a prospective juror as racially
discriminatory.

In this habeas case, petitioner-appellant Leron Porter,
a Rhode Island state prisoner who is an African-American man
convicted of murder and other crimes, claims that the prosecutor
transgressed the Batson rule in the course of jury selection. The
state supreme court disagreed, see State v. Porter (Porter I), 179
A.3d 1218, 1226-27 (R.I. 2018), and the petitioner sought federal
habeas relief. The United States District Court for the District
of Rhode Island held that the prosecutor had crossed the Batson
line but that, under the rigorous standards applicable to habeas
review, the decision of the state supreme court should not be
disturbed. See Porter v. Coyne-Fague (Porter II), 528 F. Supp. 3d
2, 9-10 (D.R.I. 2021). The petitioner appeals.

This is the rare case in which the prosecutor's
explanation for his peremptory strike was not race-neutral on its
face and, thus, violated Batson. We hold that the decision of the
state supreme court, however viewed, cannot withstand habeas
review: that decision rests on either an unreasonable application
of clearly established federal law, an unreasonable determination
of the facts, or both. Consequently, we reverse the decision of
the district court and remand with directions that the district
court grant the habeas writ, ordering the state courts to vacate
the petitioner's convictions and, unless he is tried anew within
ninety days of the district court's order, to release him.

Outcome: Reversed and remanded.

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