April 28th, 2017

​U.S. Court of Appeals for the Fifth Circuit Opinions
Chamberlin v. Fisher, Commissioner

Docket: 15-70012
Opinion Date: April 27, 2017
Judge: Costa
Areas of Law: Civil Rights, Constitutional Law, Criminal Law

After a jury convicted Lisa Jo Chamberlin of two counts of capital murder and sentenced her to death, the district court granted habeas relief on the ground that the state court erred in finding that there was no racial exclusion of jurors at her trial. Chamberlin, a white defendant, had challenged the exclusion of black jurors. The court affirmed the district court's judgment on the ground that the Mississippi court's decision was based on an unreasonable determination of the facts under 18 U.S.C. 2254(d)(2). In this case, the court explained that clear and convincing evidence, including more damning comparative juror analysis than existed in Miller-El v. Dretke or Reed v. Quarterman, rebuts the state court's finding of no discrimination. Accordingly, the court affirmed the judgment.