The Supreme Court unanimously reinstated the drug conviction of a Los Angeles man Wednesday and said the U.S. 9th Circuit Court of Appeals had overstepped its authority by second-guessing a decision of the California state courts.
The justices used the case to again send the message that federal judges had a limited role in reviewing the decisions of state courts.
Justice Anthony M. Kennedy said the 9th Circuit in San Francisco had "set aside reasonable state-court determinations of fact in favor of its own debatable interpretation of the record" in the case of Steven Collins.
A Superior Court jury in Los Angeles convicted Collins of cocaine possession 10 years ago. Because of his prior convictions for robbery and rape, he was sentenced to 25 years in prison.
Collins, who is black, accused the prosecutor of racial bias in selecting his jury. Only one black male was seated on the jury, and the defendant's lawyer objected when two black women were struck from the jury pool.
The prosecutor said the women were "too tolerant of this type of case." After considering the defense's objection, the judge accepted the prosecutor's explanation.
After his conviction, Collins appealed, but a California appeals court, the state Supreme Court and a U.S. district judge upheld the conviction and rejected his claim of racial bias.
But when Collins appealed to the 9th Circuit, its judges ruled he had been a victim of racial bias and reversed his conviction. Judge Richard A. Paez said the Supreme Court's past rulings required a prosecutor in such a situation to state a clear, nonracial reason for removing a black juror, and the prosecutor in this case failed to offer one.
California Atty. Gen. Bill Lockyer appealed the 9th Circuit's decision to the Supreme Court and came to Washington to argue the case in December. He said the 9th Circuit was overstepping its authority by second-guessing decisions made by state judges.
Ten years ago, Congress revised the Habeas Corpus Act and made it harder for state prison inmates to win a reversal of their convictions in a federal court. The new law said a federal appeal "shall not be granted" unless the state court's decision "involved an unreasonable application of clearly established federal law." Moreover, the factual decisions of state judges "shall be presumed to be correct."
Since then, the 9th Circuit and the California Department of Justice have repeatedly disagreed on how that law applies in specific cases.
In the Collins case, Kennedy said it was not clear the prosecutor's explanations for dismissing the prospective black jurors were convincing. "Reasonable minds reviewing the record might disagree," he said.
But the California courts acted reasonably in upholding Collins' conviction, and current law did not allow federal judges to reconsider the case. "Our review confirms that the court of appeals for the 9th erred, misapplying settled rules that limit role and authority," Kennedy concluded in Rice vs. Collins.
Charles Hobson, a lawyer for the Criminal Justice Legal Foundation in Sacramento, applauded the ruling.
"Federal judges are not free to substitute their own views, years after the trial, for the fact-based findings of the trial judge who was actually there," Hobson said.