Seventh Circuit -- M. C. Winston v. Ana Boatwright

M. C. Winston v. Ana Boatwright

When deft's lawyer deliberately uses all peremptory strikes to keep males off of sexual assault jury, it's ineffective assistance - but as no clear caselaw on how to assess prejudice from error, no error in state denial of habeus.

(While Batson would justify automatic reversal, and therefore the writ, the fact that deft's counsel made the choice triggers Strickland analysis, which requires a showing of prejudice.)