Berghuis v. Smith Case Brief

Facts of the Case

Atin the Kent County Circuit Court trial of respondent Smith, an African-American, the venire panel included between 60 and 100 individuals, only 3 of whom, at most, were African-American. At that time, African-Americans constituted 7.28% of the County’s jury-eligible population, and 6% of the pool from which potential jurors were drawn. The court rejected Smith’s objection to the panel’s racial composition, an all-white jury convicted him of second-degree murder and felony firearm possession, and the court sentenced him to life in prison with the possibility of parole. The U.S. Court of Appeals for the Sixth Circuit reversed a dismissal of Smith’s petition for a writ of habeas corpus based upon hisfair-cross-section claim. The warden, Mary Berghuis, filed for a petition for certiorari.

Question

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CONCLUSION

“Yes. The Supreme Court held that the Sixth Circuit erred in ruling that the Michigan Supreme Court’s decision “involved an unreasonable application of clearly established federal law.” With Justice Ruth Bader Ginsburg writing for a unanimous Supreme Court, it reasoned that Duren v. Missouri did not establish that Mr. Smith was denied his Sixth Amendment right to an impartial jury. While the Duren defendant established an absolute disparity, comparative disparity, and standard deviation of underrepresentation of women, that case did not specify the method courts must use to measure underrepresentation. Here, Mr. Smith did not provide sufficient evidence to prove that the trial court’s policies had any significant effect on the underrepresentation of African-American jurors in the area.Justice Clarence Thomas wrote separately, concurring. He challenged the Court to reconsider that the Sixth Amendment guarantees a defendant the right to a jury that represents “a fair cross section” of the community. Instead, he proposed that the right stems more from an “amalgamation of the Due Process Clause and the Equal Protection Clause.””

Case Information

Citation: 559 US 314 (2010)
Granted: Sep 30, 2009
Argued: Jan 20, 2010
Decided: Mar 30, 2010
Case Brief: 2010