Vernon Madison, a Black Alabama prisoner sentenced to death for killing a white police officer, sought federal habeas relief from his capital conviction and sentence. He argued that the state courts misapplied Batson by requiring him to prove purposeful racial discrimination before the prosecution explained its peremptory strikes, failed to consider mitigating mental-health evidence, and improperly upheld a judge’s override of an eight-to-four jury recommendation for life without parole. The Eleventh Circuit affirmed in part, reversed in part, and remanded. It rejected the mitigation claim because the sentencing courts considered Madison’s mental illness and his mother’s plea for mercy but found them outweighed by aggravating circumstances. It also rejected the judicial-override claim under Harris v. Alabama. On Batson, however, the court held that the state courts applied the wrong first-step standard: Madison needed only to present facts sufficient to raise an inference of discriminatory purpose. Six of eighteen peremptory strikes had targeted qualified Black jurors, the prosecutor had not meaningfully questioned several of them, and the case carried racial sensitivity. The court reversed on that claim and remanded for the remaining Batson steps. Judge Barkett separately criticized judicial override, while Judge Hull said that issue was not before the court.