Race discrimination in jury selection
Timothy Tyrone Foster v. Chatman
In brief
The Supreme Court ruled for Foster, finding the decision rejecting his race-discrimination claim clearly wrong and sending the case back to Georgia courts.
- Where it stands
- Decided
Decided 7-1 · May 23, 2016 · Opinion by Chief Justice Roberts
- What it’s about
- Timothy Foster argued that prosecutors struck Black prospective jurors because of race at his Georgia murder trial.
- Who it affects
- Foster's case returns to Georgia courts, but the Supreme Court did not specify what final relief he should receive.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that the state court was clearly wrong to find he had not shown intentional racial discrimination, overturned its decision (reversed it), and sent the case back to the Georgia courts (remanded).
Batson v. Kentucky bars prosecutors from excluding potential jurors because of race.
Question presented
Was there race-based discrimination of the type Batson v. Kentucky prohibits in the jury selection process of Foster’s trial?
What the Court decided
Holding
This Court has jurisdiction to review the judgment of the Georgia Supreme Court denying Foster a Certificate of Probable Cause on his Batson claim. Although this Court cannot ascertain the grounds for that unelaborated judgment, there is no indication that it rested on a state law ground that is both “independent of the merits” of Foster’s Batson claim and an “adequate basis” for that decision, so as to preclude jurisdiction. Harris v. Reed, 489 U. S. 255, The state habeas court held that the state law doctrine of res judicata barred Foster’s claim only by examining the entire record and determining that Foster had not alleged a change in facts sufficient to overcome the bar. The decision that Foster failed to show purposeful discrimination was clearly erroneous. Reversed and remanded.
- Result
- Reversed
The Court's reasoning
The Court found no indication that a separate state-law ground blocked its review. It also found clearly wrong the decision that Foster had not shown intentional discrimination.
The vote
From the opinions
“Time and again, the state courts have rejected that claim.”
What's next
The case returns to Georgia courts for further proceedings. The Supreme Court did not decide what final relief Foster should receive.
Documents
Opinions
Docket activity
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AI analysis generated: Case Briefing
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AI analysis generated: Impact Analysis
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
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Opinion added: Foster
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.