[1] The case involved a habeas corpus petition submitted by Hector Ayala, who was arrested and tried in the late 1980s for the alleged murder of three individuals during an attempted robbery of an automobile body shop in San Diego, California in April 1985.

[3] Ayala was ultimately sentenced to death, but he filed several appeals challenging the constitutionality of the trial court's decision to exclude his counsel from the hearings.

[7] In response, Justice Clarence Thomas wrote a one-paragraph concurring opinion in which he stated that Ayala's accommodations were "far sight more spacious than those in which his victims ... now rest".

[17] Additionally, the Supreme Court of the United States has held that findings with respect to a prosecutor's explanation of the reasons for their use of peremptory challenges is "entitled to 'great deference'".

[21] However, in the wake of the Oklahoma City bombing, congress passed the Antiterrorism and Effective Death Penalty Act ("AEDPA")[22] in 1996 to modify federal habeas corpus procedures.

[27] Additionally, when reviewing federal habeas corpus petitions, a petitioner must demonstrate that an error "had substantial and injurious effect or influence in determining the jury's verdict".

[30] Hector Ayala was charged with three counts of murder that allegedly occurred during an attempted robbery of an automobile body shop in San Diego, California in April 1985.

[33] The trial court ultimately concluded that the peremptory challenges were based on race-neutral criteria, and Ayala was convicted of the three counts of murder in August 1989.

[43] Applying these standards to the facts of this case, Justice Alito ruled that Ayala did not suffer any actual prejudice and that the California Supreme Court's opinion "represented an entirely reasonable application of controlling precedent".

[47] Justice Kennedy wrote that "[t]he human toll wrought by extended terms of isolation long has been understood, and questioned, by writers and commentators" and that solitary confinement "bears a further terror and peculiar mark of infamy".

[8] He wrote that the "accommodations in which Ayala is housed are a far sight more spacious than those in which his victims, Ernesto Dominguez Mendez, Marcos Antonio Zamora, and Jose Luis Rositas, now rest".

[6] Considering the evidence presented in this case, Justice Sotomayor concluded that there "is neither a factual nor a legal basis for the Court’s confidence" that the prosecution's use of peremptory challenges was race neutral.

[54] Steve Vladeck wrote that "[g]oing forward, the dispute between the majority and dissent will have an especially significant effect on cases in which trial courts conduct Batson proceedings ex parte".

[61] In an interview with Harvard Law School dean Martha Minow, Justice Kennedy explained that when he was in the Army, he was locked in a cell for four hours and "slightly tortured".