William Edward Sneed v. John E. Wetzel, Secretary, Pennsylvania Department of Corrections, et al.
DueProcess HabeasCorpus Securities
In light of the post-conviction court's finding of intentional discrimination—a finding that has not been challenged by any reviewing court—did the Third Circuit Court of Appeals violate the standard for considering an application for certificate of appealability when it held that no jurist of reason would debate the merits of the underlying Batson and ineffectiveness claims?
QUESTION PRESENTED After an evidentiary hearing, the post-conviction court found that the trial prosecutor intentionally discriminated against African-American jurors in violation of Batson v. Kentucky, 476 U.S. 79 (1986), and that appellate counsel was ineffective for failing to raise that claim on appeal. Without disturbing the lower court’s factual findings, the Pennsylvania Supreme Court reversed that ruling on appeal, and the district court denied habeas relief. The question presented is: In light of the post-conviction court’s finding of intentional discrimination—a finding that has not been challenged by any reviewing court—did the Third Circuit Court of Appeals violate the standard for considering an application for certificate of appealability when it held that no jurist of reason would debate the merits of the underlying Batson and ineffectiveness claims? i