Denial of constitutional rights to impartial jury and effective assistance of counsel

QUESTIONS PRESENTED Under this Court’s clearly established precedent, was Petitioner Andre Thomas—an African American man who, during a schizophrenic episode, killed his estranged white wife, their son, and her daughter— denied his constitutional rights: (1) to be tried by an impartial jury, when three jurors at Thomas’s capital trial expressed opposition to people of different races marrying and having children—writing on their voir dire questionnaires that such relationships are “against God’s will,” that we should “stay with our Blood Line,” and that the children of interracial relationships are denied “a specific race to belong to”—and when the jurors never disclaimed those views or said they could set them aside to consider Petitioner’s mental illness and make the individualized sentencing judgment required by the Constitution; and (2) to the effective assistance of counsel, when defense counsel did not object to, or seek to strike, any of those three jurors, and failed to ask two of them a single question about their bias.