Foster v. Chatman

Foster v. Chatman
Supreme Court of the United States
Argued November 2, 2015 Decided May 23, 2016
Full case name	Timothy Tyrone Foster, Petitioner v. Bruce Chatman, Warden
Docket no.	14-8349
Citations	578 U.S. ___ (more) 136 S. Ct. 1737; 195 L. Ed. 2d 1
Argument	Oral argument
Opinion announcement	Opinion announcement
Case history
Prior	Defendant found guilty in Floyd County Superior Court; Supreme Court of Georgia affirmed, 258 Ga. 736, 374 S.E.2d 188 (1988); cert. denied, 490 U.S. 1085 (1989). State court habeas petition denied; appeal denied by Supreme Court of Georgia; cert. granted, 135 S. Ct. 2349 (2015).
Holding
The Court has jurisdiction to review the judgment of the Georgia Supreme Court denying Foster a Certificate of Probable Cause on his Batson claim. The decision that Foster failed to show purposeful discrimination was clearly erroneous under the three-step process established by Batson. Supreme Court of Georgia reversed and remanded.
Court membership
Chief Justice John Roberts Associate Justices Anthony Kennedy · Clarence Thomas Ruth Bader Ginsburg · Stephen Breyer Samuel Alito · Sonia Sotomayor Elena Kagan
Case opinions
Majority	Roberts, joined by Kennedy, Ginsburg, Breyer, Sotomayor, Kagan
Concurrence	Alito (in judgment)
Dissent	Thomas
Laws applied
U.S. Const. amend. XIV

Foster v. Chatman, 578 U.S. ___ (2016), was a United States Supreme Court case in which the Court held that the state law doctrine of res judicata does not preclude a Batson challenge against peremptory challenges if new evidence has emerged. The Court held the state courts' Batson analysis was subject to federal jurisdiction because "[w]hen application of a state law bar 'depends on a federal constitutional ruling, the state-law prong of the court’s holding is not independent of federal law, and our jurisdiction is not precluded,'" under Ake v. Oklahoma.^[1]

It held that the petitioner, Timothy Foster, had established purposeful discrimination, and that as a result, the state habeas court and Supreme Court of Georgia had erred in denying his Batson claim that black jurors were struck from his jury pool on the basis of race. In concluding its opinion, the Court noted that "[t]wo peremptory strikes on the basis of race are two more than the Constitution allows."^[2] The court frequently cited Snyder v. Louisiana in its decision.