Upshaw v. Stephenson, No. 22-1705 (6th Cir. 2024)
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In the case under review, the appellant, Lafayette Deshawn Upshaw, was convicted of crimes associated with two separate incidents occurring on the same day: a gas station robbery and a home invasion. Following exhaustion of state court remedies, Upshaw sought habeas relief in federal court, upon which the district court granted relief on claims of ineffective assistance of counsel and violation of the Batson rule.
The ineffective assistance of counsel claim was based on trial counsel's failure to investigate potential alibi witnesses. The Batson rule violation claim was derived from the State’s use of peremptory challenges to strike six Black jurors. The Warden appealed the district court's decision, but the United States Court of Appeals for the Sixth Circuit affirmed the lower court's ruling.
The court found that the trial counsel's failure to investigate potential alibi witnesses and to request an adjournment to rectify the situation was unreasonable and prejudicial to Upshaw, constituting ineffective assistance of counsel. The court also found that the State's failure to provide race-neutral reasons for striking certain jurors, coupled with the trial court's failure to properly evaluate the State's justifications, constituted a violation of the Batson rule. The court held that even a single racially motivated peremptory strike requires relief. The court concluded that both of these errors entitled Upshaw to habeas relief.
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