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Remand of Denial of Habeas Relief to Conduct Batson Step Three Analysis

FindLaw Staff

Article by: FindLaw Staff

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Coombs v. Diguglielmo, 08-1945, concerned a chalenge to the district court's denial of defendant's request for habeas relief, claiming that the prosecutor exercised his peremptory challenges in violation of Batson.  The court remanded the case for the district court to hold an evidentiary hearing as the trial court failed to conduct a full and complete Batson step three analysis in unreasonably limiting the defendant's opportunity to prove that the prosecutor's proffered reasons for striking black jurors were pretextual, thereby improperly restricting the defendant's ability to prove discriminatory intent.

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