Foster v. Chatman
The Court held that the state law doctrine of res judicata does not preclude a Batson challenge against peremptory challenges if new evidence has emerged.
578 U.S. 488 · No. 14-8349 · 2015 term · Roberts Court
Decided May 23, 2016 · argued Nov 2, 2015
Criminal procedure · Extra-legal jury influences: jurors and death penalty
Majority opinion: John Roberts
The voteMajorityDissent
7–17 in the majority, 1 in dissent
1 dissent (8–1)
Reversed and remanded. Foster won.
What this ruling means
Reversed and remanded: the Supreme Court overturned the decision of the Georgia Supreme Court and sent the case back to that court for further proceedings that follow the Supreme Court’s ruling.
Foster was the petitioner, the side that asked the Supreme Court to review the case. “Won” means the Court gave that side the result it asked for.
From the Supreme Court Database. A justice who agreed with the result but not the reasoning counts in the majority.
Summary
The opening of the case’s Wikipedia article: what the case was about and what the Court held.
Foster v. Chatman, 578 U.S. 488 (2016), was a United States Supreme Court case in which the Court held that the state law doctrine of res judicata does not preclude a Batson challenge against peremptory challenges if new evidence has emerged. The Court held the state courts' Batson analysis was subject to federal jurisdiction because "hen application of a state law bar 'depends on a federal constitutional ruling, the state-law prong of the court’s holding is not independent of federal law, and our jurisdiction is not precluded,'" under Ake v. Oklahoma.
It held that the petitioner, Timothy Foster, had established purposeful discrimination, and that as a result, the state habeas court and Supreme Court of Georgia had erred in denying his Batson claim that black jurors were struck from his jury pool on the basis of race. In concluding its opinion, the Court noted that "wo peremptory strikes on the basis of race are two more than the Constitution allows." The court frequently cited Snyder v. Louisiana in its decision.
Data notes
The text is Wikipedia’s (CC BY-SA 4.0), matched to the case by its citation, docket number or name and year, and is not checked against the opinion. The site keeps the article’s opening section, ending on its last full sentence. The one-sentence summary under the title is the Decisions list’s: Wikipedia’s own ruling sentence, or, tagged “AI-written”, one Claude wrote from this opening.
How the justices voted
Each justice who took part, placed by their Martin–Quinn ideology score for the 2015 term. Filled: the 7 in the majority. Hollow: the 1 in dissent. Colour is the party of the president who appointed them.
Majority(7)
John RobertsWrote the majority opinion
Samuel AlitoWrote a concurrence
Sonia SotomayorJoined the majority
Ruth GinsburgJoined the majority
Elena KaganJoined the majority
Stephen BreyerJoined the majority
Anthony KennedyJoined the majority
Dissent(1)
Clarence ThomasWrote a dissent
Data notes
Each justice’s vote and what they wrote are from the justice-centered file of the Supreme Court Database. “Wrote a concurrence” means the justice sided with the majority and wrote separately; a justice who dissented in part is counted on the side they took overall. A justice who wrote nothing is listed as joining their side.
Positions are each justice’s Martin–Quinn score for the case’s term, the same scores as the Ideology page: negative is more liberal, positive more conservative. A score sums up a justice’s votes across the whole term, so it says where they usually sit, not why they voted as they did here. The median line is the Court’s median justice that term.
The parties
Who brought the case to the Court, who answered it, and how it got there.
- Petitioner
- FosterPrisoner, inmate of penal institution
- Respondent
- ChatmanGovernmental official, or an official of an agency established under an interstate compact (Georgia)
- Reached the Court by
- Certiorari (the Court chose to hear it)
Data notes
The names are the two sides of the case’s title. The description under each is the Supreme Court Database’s category for that party, in its own wording. The petitioner is the side that asked the Supreme Court to review the decision below. “Why it was taken” appears only when the majority opinion says lower courts disagreed or were unsure about the question; reasons that would fit any case (“to resolve the question presented”, “an important question”) are left out.
The law at issue
The law the Court was asked to apply, and the kind of power it used to decide.
- Provision
- Fourteenth Amendment (equal protection)
- Kind of law
- Constitutional Amendment
- Decided by
- Judicial review (state level)
Data notes
The Supreme Court Database codes the main constitutional provision, statute or court rule each case turned on, and the basis of the decision: judicial review of a federal or state law, interpreting a statute, supervising the lower courts, and so on. A case can rest on more than one. “Overruled” counts only where the majority opinion says so.
Timeline
What happened at the Court and how the case got there, newest first.
- May 23, 2016DecidedDecided · Decided 7–1: reversed and remanded. Foster won.
- Nov 2, 2015ArguedArgued · Oral argument before the Court.
- Not datedTaken upTaken up · The Supreme Court agreed to hear the case (certiorari).
- Not datedCourt belowCourt below · Decided by the Georgia Supreme Court: petition denied or appeal dismissed.
- Not datedBeganBegan · The case began in the Georgia trial court.
Data notes
From the Supreme Court Database: the court the case began in, the court whose decision the Supreme Court reviewed and what that court did, how the case came to the Court, and the dates of argument and decision. The database does not date the steps in the lower courts. Court names are the database’s.
Other decisions on the same issue
14 other argued cases since 1946 on extra-legal jury influences: jurors and death penalty, newest first.
- United States v. Tsarnaev142 S. Ct. 1024Mar 4, 2022 · 142 S. Ct. 1024Criminal procedure6–36–3 band
- Flowers v. Mississippi139 S. Ct. 2228Jun 21, 2019 · 139 S. Ct. 2228Criminal procedure7–27–2 band
- Jeffrey Uttecht, Superintendent, Washington State Penitentiary v. Cal Coburn Brown551 U.S. 1Jun 4, 2007 · 551 U.S. 1Criminal procedure5–45–4 band
- Derrick Morgan v. Illinois504 U.S. 719Jun 15, 1992 · 504 U.S. 719Criminal procedure6–36–3 band
- Ross v. Oklahoma487 U.S. 81Jun 22, 1988 · 487 U.S. 81Criminal procedure5–45–4 band
- Buchanan v. Kentucky483 U.S. 402Jun 24, 1987 · 483 U.S. 402Criminal procedure6–36–3 band
- Gray v. Mississippi481 U.S. 648May 18, 1987 · 481 U.S. 648Criminal procedure5–45–4 band
- Darden v. Wainwright, Secretary, Florida Department of Corrections477 U.S. 168Jun 23, 1986 · 477 U.S. 168Criminal procedure5–45–4 band
- Lockhart, Director, Arkansas Department of Corrections v. McCree476 U.S. 162May 5, 1986 · 476 U.S. 162Criminal procedure6–36–3 band
- Wainwright, Secretary, Florida Department of Corrections v. Witt469 U.S. 412Jan 21, 1985 · 469 U.S. 412Criminal procedure7–27–2 band
- Adams v. Texas448 U.S. 38Jun 25, 1980 · 448 U.S. 38Criminal procedure8–18–1 band
- McGautha v. California402 U.S. 183May 3, 1971 · 402 U.S. 183Criminal procedure6–36–3 band
- Maxwell v. Bishop, Penitentiary Superintendent398 U.S. 262Jun 1, 1970 · 398 U.S. 262Criminal procedure6–18–1 band
- Witherspoon v. Illinois et al.Landmark · Capital punishment391 U.S. 510Jun 3, 1968 · 391 U.S. 510Criminal procedureLandmark · Capital punishment6–36–3 band
Data notes
Every other orally argued case with a clear vote, from the 1946 term on, that the Supreme Court Database files under the same issue as this one. The database gives each case one issue from a list of about 270 (abortion, search and seizure of vehicles, the death penalty, and so on), whatever law it turned on.
Official record
Read the full opinion on Justia, the argument audio on Oyez and Wikipedia. Case data from the Supreme Court Database, Version 2026 Release 01, through the 2025 term.