Abelino Manriquez v. Ralph Diaz, Acting Secretary, California Department of Corrections and Rehabilitation

Petitioner Abelino Manriquez was enslaved, beaten daily, and tortured while growing up on a Mexican farm. He was later convicted of murdering four people in California. Manriquez’ evidence and jury argument to be spared the death penalty rested on his horrific childhood abuse. Unknown to Manriquez’ counsel, the jury foreperson had endured remarkably similar abuse for years. Based on this experience, she had categorically concluded, before hearing the evidence, that being abused does not excuse crimes. She argued in deliberations that Manriquez’ evidence did not warrant leniency because her similar past showed that abused children can turn out law-abiding. The jury recommended the death penalty, which the court imposed. Manriquez petitioned the California Supreme Court for habeas corpus, arguing that the juror was biased. Over two dissents, the California Supreme Court denied relief. The majority acknowledged that federal courts of appeals have held that a juror is unconstitutionally biased when the juror’s experience is so similar to the case facts that a reasonable juror could not be impartial. It labeled these cases “nonprecedential.” Two justices dissented, concluding that the juror was biased because she had a predetermined, categorical opinion and did not individually consider the evidence at trial. The question presented is: What test determines whether a juror’s life experiences are so similar to facts in the case that the juror must be disqualified for bias under the Sixth and Fourteenth Amendments?