Amadeo v. Zant

In Amadeo v. Zant, 486 U.S. 211 , 108 S. Ct. 1771 (1988), the petitioner first raised a constitutional challenge to the composition of his juries on direct appeal to the Georgia Supreme Court, based upon a newly discovered memorandum from the District Attorney Offices of Putnam County evidencing a scheme to intentionally underrepresent black people and women on the master jury lists from which all grand and traverse juries were drawn. See id. at 217-218, 108 S.Ct. at 1774. The state courts refused to hear the claim because it had not been raised earlier, but the federal district court judge found that petitioner had established sufficient cause and prejudice to excuse the procedural default. See id. at 219-220, 108 S.Ct. at 1775. A divided panel of this Court reversed, but the Supreme Court reversed this Courts decision, finding that sufficient evidence in the record supported the district courts factual findings and that this Court should not have set them aside. See id. at 229, 108 S.Ct. at 1780.