Washington v Roberts

Washington appealed the denial of his habeas petition. The panela affirmed. It held that at the time of his state direct appeal, there was no United States Supreme Court case which would have required Kansas to use another rule in its Batson analysis than its race as sole factor test and that the application was not unreasonable given the deference given to trial court determinations of credibility of potential jurors. It held the Miranda analysis of the Kansas Supreme Court was not unreasonable given Washington voluntarily went to the station, stayed in a victim’s room with a television, was not in handcuffs and was not told he faced arrest for outstanding warrants. It held there was no ineffective assistance of counsel because the state district court ruled Washington’s account of the interrogation was not credible and thus his statements would have come in anyway. It finally held that the Kansas Supreme Court decision about the prosecutor’s statements in closing argument was not unreasonable as the comment was not inflammatory and the jury was given clear instructions about Washington’s post-traumatic stress disorder defense.