Davis v. Ayala

Davis v. Ayala
Supreme Court of the United States
Argued March 3, 2015
Decided June 18, 2015
Full case nameRon Davis, Acting Warden, Petitioner v. Hector Ayala
Docket no.13–1428
Citations576 U.S. 257 (more)
135 S. Ct. 2187; 192 L. Ed. 2d 323
ArgumentOral argument
Case history
PriorAyala v. Wong, 756 F.3d 656 (9th Cir. 2013); cert. granted, 135 S. Ct. 401 (2014).
SubsequentRehearing denied, 136 S. Ct. 14 (2015); on remand, Ayala v. Davis, 813 F.3d 880 (9th Cir. 2016); Ayala v. Chappell, 829 F.3d 1081 (9th Cir. 2016); cert. denied, 138 S. Ct. 244 (2017).
Holding
Although the defendant's attorney was excluded from a Batson hearing, any error that may have occurred was harmless because the defendant did not suffer actual prejudice
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia · Anthony Kennedy
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Case opinions
MajorityAlito, joined by Roberts, Scalia, Kennedy, Thomas
ConcurrenceKennedy
ConcurrenceThomas
DissentSotomayor, joined by Ginsburg, Breyer, Kagan
Laws applied
Antiterrorism and Effective Death Penalty Act of 1996, 28 U.S.C. § 2254(d)

Davis v. Ayala, 576 U.S. 257 (2015), was a case in which the Supreme Court of the United States upheld a death sentence of a Hispanic defendant despite the fact that all Blacks and Hispanics were rejected from the jury during the defendant's trial.[1] The case involved a habeas corpus petition submitted by Hector Ayala, who was arrested and tried in the late 1980s for the alleged murder of three individuals during an attempted robbery of an automobile body shop in San Diego, California in April 1985.[2] At trial, the prosecution used peremptory challenges to strike all Black and Hispanic jurors who were available for jury service.[2] The trial court judge allowed the prosecution to explain the basis for the peremptory challenges outside the presence of Ayala's counsel, "so as not to disclose trial strategy".[3] Ayala was ultimately sentenced to death, but he filed several appeals challenging the constitutionality of the trial court's decision to exclude his counsel from the hearings.[4]

In a 5–4 opinion written by Justice Samuel Alito, the Supreme Court held that even if the trial court committed error, the error was harmless and that Ayala did not suffer any actual prejudice.[5] Justice Sonia Sotomayor wrote a dissenting opinion in which she argued that Ayala's sentence should be reversed because the exclusion of Ayala's counsel from the hearings "substantially influenced the outcome" of the case.[6] Additionally, Justice Anthony Kennedy wrote a separate concurring opinion in which he questioned the propriety of Ayala's placement in solitary confinement.[7] In response, Justice Clarence Thomas wrote a one-paragraph concurring opinion in which he stated that Ayala's accommodations were "far sight more spacious than those in which his victims ... now rest".[8]

Commentators have described the case as "important" and note that will likely have a "significant effect" on similar cases in the future.[9] However, some analysts have described the outcome as "particularly unjust".[10] Justice Kennedy's concurring opinion also received significant coverage from the media,[11] and some analysts suggested that solitary confinement may become a "new battleground" for Justice Kennedy.[12] One commentator described Justice Kennedy's concurring opinion as "the single most surprising and heartening development of the term".[13]

  1. ^ Davis v. Ayala, No. 13-1428, 576 U.S. ___ (2015), slip op. at 1–2, 29.
  2. ^ a b Davis, slip op. at 1–2.
  3. ^ Davis, slip op. at 1.
  4. ^ Davis, slip op. at 4–8.
  5. ^ Davis, slip op. at 9–10, 28–29.
  6. ^ Davis, slip op. at 15 (Sotomayor, J., dissenting).
  7. ^ Davis, slip op. at 1–5 (Kennedy, J., concurring).
  8. ^ Davis, slip op. at 1 (Thomas, J., concurring).
  9. ^ See, e.g., Brandon Garrett, UVA Law Faculty Comment on Supreme Court Decisions, University of Virginia School of Law; Steve Vladeck, Opinion analysis: How habeas courts should assess harmless error in a procedural Batson challenge, SCOTUSblog (Jun. 18, 2015, 2:33 PM).
  10. ^ Lincoln Caplan, The Destruction of Defendants' Rights, The New Yorker (June 21, 2015).
  11. ^ Steve Vladeck, Opinion analysis: How habeas courts should assess harmless error in a procedural Batson challenge, SCOTUSblog (Jun. 18, 2015, 2:33 PM) (noting that the case was "noteworthy for an unusually testy exchange between two of the Justices in the majority"); Mark Joseph Stern, 20 Years in a Windowless Cell, Slate (June 19, 2015) (discussing significance of Justice Kennedy's concurring opinion).
  12. ^ Matt Ford, Justice Kennedy Denounces Solitary Confinement, The Atlantic (June 18, 2015).
  13. ^ Marty Lederman, Supreme Court Breakfast Table, Slate (July 2, 2015).