Foster v. Chatman

PETITIONER: Timothy Tyrone Foster
RESPONDENT: Bruce Chatman, Warden
LOCATION: Superior Court of Floyd County, Georgia

DOCKET NO.: 14-8349
DECIDED BY: Roberts Court (2016- )
LOWER COURT: State trial court

CITATION: 578 US (2016)
GRANTED: May 26, 2015
ARGUED: Nov 02, 2015
DECIDED: May 23, 2016

ADVOCATES:
Stephen B. Bright - for the petitioner
Beth A. Burton - for the respondent

Facts of the case

In 1986, Timothy Tyrone Foster, an 18-year-old black man, was charged with murdering Queen White, an elderly white woman. At the trial, the prosecution used peremptory strikes against all four of the qualified black jurors. Pursuant to the Supreme Court’s decision in Batson v. Kentucky, which prohibits the use of peremptory strikes on the basis of race, the defense objected to those strikes, and the burden shifted to the prosecution to prove that there were race-neutral explanation for the strikes. The prosecution provided reasons, and the trial court held that the reasons were sufficient. An all-white jury convicted Foster of murder and imposed the death penalty.

Foster filed a motion for post-judgment discovery regarding the prosecution’s notes during jury selection and a motion for a new trial, both of which the trial court denied. The Georgia Supreme Court affirmed the trial court’s decisions, and the U.S. Supreme Court denied certiorari. Foster  petitioned for a writ of habeas corpus in Butts County Superior Court and submitted a new Batson challenge based on the prosecutor's notes obtained through the Georgia Open Records Act. The court denied Foster's petition. The Georgia Supreme Court affirmed the denial of the writ. The U.S. Supreme Court granted certiorari. 

Question

Was there race-based discrimination of the type Batson v. Kentucky prohibits in the jury selection process of Foster’s trial?

Media for Foster v. Chatman

Audio Transcription for Oral Argument - November 02, 2015 in Foster v. Chatman

Audio Transcription for Opinion Announcement - May 23, 2016 in Foster v. Chatman

John G. Roberts, Jr.:

I have the opinion of the Court in case 14-8349, Foster versus Chatman.

In August 1989, police found Queen Madge White, a 79-year-old widow, dead on the floor of her home in Rome, Georgia.

She had been sexually assaulted and strangled to death.

Timothy Foster confessed to killing White, and White's possessions were recovered from Foster's home and from his sisters.

Foster argued, however, that the confession should not be admitted and the drugs and alcohol lowered his culpability.

A jury nonetheless convicted Foster of the murder and he was sentenced to death.

This case focuses on the jury selection at Foster's trial.

Under Georgia law, the prosecution was allotted 10 peremptory strikes, which allowed the prosecution to remove 10 prospective jurors from the jury.

The prosecution used a peremptory strike against each Black prospective juror who was considered for service.

Now it is unconstitutional to strike a prospective juror on account of race.

So the prosecution offered race-neutral reasons for each strike.

The trial court and then the Georgia Supreme Court accepted those various reasons for the strikes.

We granted certiorari to review that decision.

Now a brief word is in order about the evidence in this case.

Most cases of this sort involved trial transcripts, records and lower court opinions.

In this case, however, we have a copy of the file used by the prosecution during jury selection.

That file contains the following documents.

First, lists containing the names of each prospective juror.

The names of the Black prospective jurors are highlighted in bright green with a notation that green highlighting “represents Blacks”.

Second, a list titled definite No's.

That list containing six names including the names of each Black prospective juror.

Third, a typed document stating that “if it comes down to having to pick one of the Black jurors” one particular one might be acceptable.

Fourth, handwritten notes identifying three Black prospective jurors as B#1, B#2 and B#3.

Fifth, questionnaires filled out by several Black prospective jurors, on each the prospective juror's race is circled and sixth, a handwritten document containing the following note, “no, no Black church” referring to the church to which one of the Black prospective jurors belonged.

The word Black is underlined.

Now in light of the documents in the file and our independent examination of the record we conclude that the prosecutions purportedly raised neutral reasons for striking at least two of the Black prospective jurors; Marilyn Garrett and Eddie Hood were pretextual and that the strikes were instead based, in at least substantial part, on racial discrimination.

First, Marilyn Garrett, according to the state it was prepared to seat Garrett pm the jury and only made a last-minute decision to strike her after another juror was excused on the morning of the striking of the jury.

That explanation is contradicted by the record which shows Garrett's name on the list titled “definite No's”.

That list had only six names and it meant what it said.

There was no way that Garrett would serve.

Sarah from Law Aspect

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