Foster v. Chatman Case Brief

Facts of the Case

Petitioner Timothy Foster was convicted of capital murder and sentenced to death in a Georgia court. During jury selection at his trial, the State used peremptory challenges to strike all four black prospective jurors qualified to serve on the jury. Foster argued that the State’s use of those strikes was racially motivated, in violation ofThe trial court rejected that claim, and the Georgia Supreme Court affirmed. Foster then renewed his Batson claim in a state habeas proceeding. While that proceeding was pending, Foster, through the Georgia Open Records Act, obtained from the State copies of the file used by the prosecution during his trial. Among other documents, the file contained copies of the jury venire list on which the names of each black prospective juror were highlighted in bright green, with a legend indicating that the highlighting “represents Blacks.” The file further contained notes with “N” (for “no”) appearing next to the names of all black prospective jurors, and a list title “Definite NO’s” containing six names, including the names of all of the qualified black prospective jurors. The state habeas court denied relief. It noted that Foster’s Batson claim had been adjudicated on direct appeal, and that Foster failed to show any change in the facts sufficient to overcome the state law doctrine of res judicata. The Georgia Supreme Court denied Foster the Certificate of Probable Cause necessary to file an appeal. The U.S. Supreme Court granted certiorari.




“The evidence was sufficient to establish that there was purposeful discrimination of the type that Batson v. Kentucky prohibits in the jury selection process of Foster’s trial. Chief Justice Roberts delivered the opinion of the 7-1 majority. The Court held that the third step of a Batson challenge, which requires the defendant to show that the strikes of prospective jurors based on race was purposeful discrimination, was clearly met in this case, and the state court erred in finding otherwise. Although the prosecutor offered a long list of reasons those jurors were struck, the evidence from the prosecution’s notes that Foster obtained through the Georgia Open Records Act shows that the first five names on the prosecution’s “definite NOs” list were of five black jurors, all of whom were eventually struck. Therefore, the evidence shows that the prosecution was never seriously considering allowing the prospective jurors in question to serve, and the reasons for striking them were likely pretextual. Further, the fact that several white jurors with the same traits as the black jurors in question were allowed to serve on the jury, the prosecution’s explanations for striking the jurors in question shifted over time, there were misrepresentations of the record to support the strikes, and the prosecution notes continually highlighted race lend credible support to Foster’s argument that he suffered purposeful discrimination.In his opinion concurring in the judgment, Justice Samuel A. Alito, Jr. wrote that the Georgia courts’ decisions to deny Foster’s Batson challenge was likely based on state law restricting the opportunity to relitigate previously rejected claims. Because the U.S. Supreme Court does not have jurisdiction to review state court decisions on state law claims, the proper course of action in a case like this one would be for the Court to decide the relevant question of federal law that influenced the state court’s decision and remand the case to allow the state court to decide the issue in light of the Supreme Court’s clarification.Justice Clarence Thomas wrote a dissent in which he argued that the Supreme Court likely did not have proper jurisdiction over this case because the state courts seemed to base their decisions on issues of procedural state law. Therefore, the Court should have vacated the lower decision and remanded for clarification regarding whether the state court’s decision implicated an issue of federal law before deciding this case. Justice Thomas also argued that, because the trial court’s decision was essentially a credibility determination, the majority should have granted more deference to that decision, which the new evidence did not invalidate.”

Case Information

Citation: 578 US (2016)
Granted: May 26, 2015
Argued: Nov 2, 2015
Decided: May 23, 2016
Case Brief: 2016