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Pitchford v. Cain · ¶4

In this capital case, the Mississippi trial court never conducted the essential third step of the Batson inquiry. The Mississippi Supreme Court affirmed Pitchford's conviction and death sentence—but only by concluding that Pitchford had waived his opportunity to rebut the prosecutor's race- neutral reasons as pretextual at Batson's third step. On habeas review, the U. S. District Court determined that Pitchford had not waived rebuttal and that the Mississippi Supreme Court's contrary conclusion was unreasonable. See 28 U. S. C. § 2254(d). The District Court therefore granted relief to Pitchford. But the U. S. Court of Appeals for the Fifth Circuit reversed. This Court granted certiorari, 607 U. S. 1094 (2025), and we now reverse the judgment of the U. S. Court of Appeals.
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