Wesley Ruiz v. Texas
DueProcess HabeasCorpus EmploymentDiscrimina
Does Peria-Rodriguez apply to Petitioner's evidence that at least one juror relied on anti-Hispanic racial stereotypes and animus to find that he was a future danger and sentence him to death?
QUESTION PRESENTED CAPITAL CASE In Petia-Rodriguez v. Colorado, 580 U.S. 206 (2017), this Court held that when a juror “relied on racial stereotypes or animus to convict a criminal defendant, the Sixth Amendment requires that the no-impeachment rule [under a state rule of evidence] give way in order to permit the trial court to consider the evidence of the juror’s statement and any resulting denial of the jury trial guarantee.” Jd. at 225. In Buck v. Davis, 580 U.S. 100 (2017), this Court held that discrimination is “especially pernicious in the administration of justice,” id. at 124, and recognized that false notions equating race or ethnicity with future dangerousness are a “particularly noxious strain of racial prejudice,” id. at 121. In light of Peria-Rodriguez and Buck, Wesley Ruiz, a Hispanic man, sought to introduce juror statements employing well-established stereotypes of Hispanic men—referring to Mr. Ruiz as an “animal” and a “mad dog”—and describing an increased in the number of Hispanics in the community as making the community “worse” and more violent. These racial stereotypes and animus influenced the jury’s decision—not “to convict,” as in Peria-Rodriguez—but regarding whether Mr. Ruiz would be dangerous in the future, and therefore deserved the death sentence. The state court rejected Mr. Ruiz’s claim without addressing the evidence that the death sentence resulted from racial animus. The question presented is: Does Peria-Rodriguez apply to Petitioner’s evidence that at least one juror relied on anti-Hispanic racial stereotypes and animus to find that he was a future danger and sentence him to death? i