Miller-El v. Cockrell

Summary

The Supreme Court held that a habeas petitioner seeking a certificate of appealability need only show that reasonable jurists could debate the district court’s resolution of the constitutional claims or that the issues deserve encouragement to proceed further. Applying this standard to the petitioner’s Batson jury-selection claim, the Court concluded that a certificate of appealability should have issued and emphasized that the threshold inquiry must not become a decision on the merits.

Holdings

1. A certificate of appealability may issue when the petitioner demonstrates that reasonable jurists could debate whether the district court's resolution of the constitutional claim was correct or that the issues deserve encouragement to proceed further. The petitioner need not show that he will ultimately prevail on habeas relief.
2. A court of appeals may not deny a certificate of appealability by definitively resolving the merits of the habeas claim first. Before issuance of a certificate, the court's review is limited to determining whether the constitutional claim is debatable among jurists of reason.
3. Miller-El made the substantial showing required for a certificate of appealability because the evidence of racially disparate peremptory strikes, disparate questioning, jury shuffling, comparative juror treatment, and historical discrimination made the district court's rejection of his Batson claim debatable among reasonable jurists.
4. The Fifth Circuit improperly merged the requirements of 28 U.S.C. §§ 2254(d)(2) and 2254(e)(1) and applied the merits standards too demanding a manner at the certificate-of-appealability stage.

Questions Presented

1. What standard governs a state prisoner's request for a certificate of appealability under 28 U.S.C. § 2253(c) after denial of habeas relief on the merits?
2. May a court of appeals decide the merits of the habeas claim before determining whether to issue a certificate of appealability?
3. Did Miller-El make the substantial showing required for a certificate of appealability on his Batson equal-protection claim?

Disposition

reversed_and_remanded