Batson Habeas.
In holding that sufficient inference of racial discrimination at voir dire was not established by petitioner, since although the court sua sponte offered a nondiscriminatory reason for the strike, it was not generally indifferent to the racial composition of the jury, the state supreme court's denial of state Habeas was not an unreasonable application of the law.
http://media.ca1.uscourts.gov/pdf.opinions/14-1953P-01A.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.