Full opinion text
OPINION SMITH, Circuit Judge. Twenty-five years ago, petitioner Terrance Williams was tried and convicted of first degree murder for the killing of Amos Norwood. A jury then returned a sentence of death. After two decades of appeals in the Pennsylvania state courts, Williams filed a petition for federal habeas review pursuant to 28 U.S.C. § 2254. The District Court denied the petition but certified two questions for our review, to wit: (1) whether trial counsel was constitutionally ineffective during the penalty phase of trial, and (2) whether the Commonwealth exercised its peremptory strikes in a racially discriminatory manner in violation of Batson v. Kentucky, 476 U.S. 79, 106 S.Ct. 1712, 90 L.Ed.2d 69 (1986). We permitted Williams to expand the certificate of appealability to include a question regarding the constitutional propriety of the trial court’s accomplice liability instructions. We conclude that each issue is without merit and will affirm. I The story of Terrance Williams is reminiscent of Dr. Jekyll and Mr. Hyde. As Dr. Jekyll, Williams was a local football star, the quarterback of the Germantown High School team that won the Philadelphia Public League championship in 1982. He was presented with the sportsman of the year award by the Philadelphia Board of Sports Officials, and he was recruited by at least eight different collegiate institutions. Nearly all of Williams’ coaches and teachers described him as mild-mannered, law-abiding, and honest. In 1983, Williams graduated from Germantown High and matriculated to Cheney State College in Philadelphia. In the estimation of one of his instructors, Williams was “highly respected and admired by his teacherfs] and all of his classmates.” He was “[n]ot only ... the star of the school’s football team, but [was] also ... a classmate and student who showed respect for others and accepted his popularity with modesty.” But apparently Terrance Williams had a sinister side. In the dead of night on Christmas Eve in 1982, a sixteen-year-old Williams broke into the Philadelphia residence of Don and Hilda Dorfman, aged sixty-nine and sixty-four, respectively. He entered Mrs. Dorfman’s bedroom, wakened her by pressing a .22 caliber Winchester rifle to her neck, and then pulled a bedsheet over her face. When Mrs. Dorfman attempted to remove the sheet, Williams ordered her to stop “or her fucking head would be blown off.” Williams then fired the rifle three times into the wall to show the victims he was serious. Williams and an accomplice ransacked the home before making off with cash, jewelry, and the Dorfmans’ automobile. It was not long before Williams was apprehended and criminally charged for robbing and terrorizing the Dorfmans. Although his age placed him under the jurisdiction of the juvenile court, the Commonwealth moved to certify Williams as an adult. In an attempt to avoid certification, Williams produced no fewer than eight witnesses who attested to his stable home life, loving parents, and supportive extended family. Every character witness interviewed by the Commonwealth believed Williams to be innocent. Even his own attorney would testify years later, “I didn’t feel in my own mind of mind[s] and heart of hearts that [Williams] was involved in the matter.” Such was the nature of Williams’ dual existence. In spite of the efforts to avoid it, Williams was certified to stand trial as an adult. He was released pending trial, however, and in January of 1984, he embarked in earnest on a crime spree that would continue for the better part of six months. Williams’ next victim was a fifty-one-year-old man named Herbert Hamilton, an individual from whom Williams had been receiving money in exchange for sex. This relationship, like much else in Williams’ life, was kept hidden from most who knew him. Hamilton apparently threatened to publicize the secret, so Williams took action. On January 26, 1984, Williams called on Hamilton at his home. The two eventually retired to the bedroom and, as they proceeded toward the bed, Williams withdrew a concealed ten-inch butcher knife and attempted to stab Hamilton. Hamilton fought back, wrestled the knife from Williams, and stabbed Williams in the chest. Hamilton then dropped the knife and ran into the kitchen to telephone for assistance. Meanwhile, Williams retrieved a nearby baseball bat, chased after Hamilton, and beat him with the bat until Hamilton was bloody and severely wounded. Williams then recovered the butcher knife and stabbed Hamilton approximately twenty times — twice in the head, ten times in the back, once in the neck, four times in the chest, and once each in the abdomen, arm, and thumb. Finally, Williams drove the butcher knife through the back of Hamilton’s neck until it protruded through the other side. He then doused Hamilton’s body with kerosene and unsuccessfully attempted to set fire to it. When police officers later entered the apartment, they found Hamilton’s kerosene-soaked body with the knife jammed through his neck; on the bathroom mirror, the phrase “I loved you” was scrawled in toothpaste. Williams was then seventeen. The Hamilton murder remained unsolved at the time that Williams went to trial for the Dorfman robbery in February of 1984. Williams maintained his innocence of the robbery throughout trial. He and his counsel mustered at least nine character witnesses who testified that Williams was a peaceful, law-abiding, and honest young man. The jury was not persuaded. They returned a conviction for two counts of robbery as felonies of the first degree, one count of burglary, one count of simple assault, one count of unauthorized use of an automobile, and one count of conspiracy. Williams was nevertheless released pending sentencing. Tragically, his crime spree continued. On June 11, 1984, Williams and a friend, Marc Draper, were gambling with several others on a street corner in the West Mount Airy neighborhood of Philadelphia. It was not long before both young men lost all of their money. While brainstorming potential means by which to recoup their losses, Williams said that he knew a man who lived nearby from whom they could extort cash. According to Williams, this individual — fifty-six-year-old Amos Nor-wood — was a closeted homosexual. With a plan that they would threaten to reveal Norwood’s secret to his wife, Draper and Williams set off for Norwood’s apartment. When they arrived at Norwood’s residence, Williams told Draper to wait outside. Williams emerged with $10 in cash approximately twenty minutes later. Williams and Draper were apparently satisfied with this amount because they returned to the street corner to resume gambling. A short time later, Norwood drove by the corner in his blue Chrysler LeBaron. When he spotted the vehicle, Williams said, “There goes my uncle,” flagged down the car, and entered via the passenger side door. Norwood then drove away. The blue LeBaron returned to the intersection several minutes later, whereupon Williams exited the vehicle, approached Draper, and said quietly, “Play it off like you going home, like you want a ride home, and we gonna take some money.” Draper understood Williams to be proposing a robbery. The two then got inside Norwood’s automobile and Draper began to provide false directions to his “home.” In reality, Draper’s directions led Nor-wood to a secluded area adjacent to the Ivy Hill Cemetery. Once there, Draper reached over the backseat, grabbed Nor-wood from behind and ordered him “to be quiet and get out of the car.” Norwood stopped the vehicle and complied. Williams and Draper then led Norwood into the cemetery and ordered him to lie facedown near a tombstone. A quick search of Norwood’s person revealed $20 hidden in his sock. At this point, Norwood began to plead for his life. The two assailants responded by removing Norwood’s clothing and tying him up; Norwood’s hands were bound behind his back with his shirt, his legs were bound together with his pants, and his socks were forcefully jammed into his mouth. Once Norwood was bound, Williams said to Draper, “Wait, I’m going to the car. We’re getting ready to do something.” And he walked off. Williams returned with a tire iron and a socket wrench, the latter of which he gave to Draper. Draper, seemingly having second thoughts, urged Williams to leave. Williams replied, “I know what I’m doin, I know what I’m doin. Don’t worry about it, I know what I’m doin.” He then began battering Norwood’s head with the tire iron. When he noticed that Draper was frozen in place, Williams said, “Man, you with me[?] We got to do this together.” Draper then sprung into action himself, striking Norwood repeatedly with the socket wrench. This violent scene continued until Norwood lay motionless and dead. Draper later recalled that there was blood everywhere. On the day of his second murder, Williams was four months past his eighteenth birthday. Williams and Draper soon parted ways. Draper reported to work, while Williams took Norwood’s automobile downtown to meet a friend, Ronald Rucker. Rucker noticed that Williams was “hyper” and asked him if everything was okay. Williams then disclosed that he had just “offed a guy” named Amos. Although Rucker initially did not believe his friend, he began to reconsider after observing blood stains on Williams’ shoes. Later that night, Williams told Rucker he was “going to get some gas from a gas station to go back to the scene of the crime.” Rucker surmised that Williams intended to burn Norwood’s body. That is precisely what Williams did. Williams and Draper were eventually undone by their use of a credit card and telephone calling card — both in Norwood’s name — that they had taken from Nor-wood’s automobile. Philadelphia police traced use of the calling card back to Rucker; upon questioning, he implicated Williams and Draper. When his interview with law enforcement concluded, Rucker informed Williams that he had provided police with Williams’ last name. Panicked, Williams boarded a bus bound for San Francisco. In the meantime, Draper was arrested and promptly confessed. He also told police about the Herbert Hamilton killing. With this information, officers proceeded to obtain a warrant for Williams’ arrest. Approximately halfway through his cross-country bus ride, Williams telephoned his girlfriend, Marlene Rogers. Rogers informed him about the outstanding arrest warrant, and urged her boyfriend to return to Philadelphia so that he could defend the charges against him. Her entreaty was apparently convincing, for Williams promptly boarded an airplane and returned east. On July 23, 1984, he arranged to be arrested in the Philadelphia office of his attorney, Ronald White. Williams’ mother notified a reporter from the Daily News that her son would surrender to authorities in White’s office. Before his arrest, Williams told the newspaper, “I wanted to come back and clear my name.” The reporter snapped photographs as Williams was led out of White’s office in handcuffs. Two days later, Williams was sentenced to twelve-and-a-half to twenty years’ imprisonment for his participation in the Dorfman robbery. In February 1985, he was tried and convicted of third degree murder for the Hamilton killing. Finally, a jury trial for the Norwood murder commenced in January of 1986 in the Philadelphia Court of Common Pleas. Draper testified for the Commonwealth and detailed the manner in which he and Williams guided Norwood to the Ivy Hill Cemetery, robbed and bound him, and then beat him to death. Williams later took the stand in his own defense and pinned the murder on Draper and another individual, Michael Hopkins. The jury rejected Williams’ testimony and returned a conviction for first degree murder, robbery, and conspiracy. The trial’s penalty phase began immediately after the jury announced its verdict. The Commonwealth introduced evidence that Williams was recently convicted of armed robbery and third degree murder. Williams, in turn, presented three witnesses in mitigation. His mother, Patricia Kemp, described her son’s athletic success and testified that he was well-liked and respected by those who knew him. She also characterized Williams’ stepfather as a verbally abusive alcoholic who routinely berated her son and once pushed him down a flight of stairs. Ms. Kemp denied participating in any abuse herself. Marlene Rogers, Williams’ girlfriend and the mother of his thirteen-month-old child, said that Williams was a “very supportive father” and had never been violent towards her or anyone she knew. The defendant’s last mitigation witness added little, rambling that “we all have sinned and come short of the glory of God.... We all have committed murder. We all have stolen some things that we should not have done. We all have committed adultery. I don’t believe you should kill another person. Blood will be on your hands.” After witness testimony was complete, Williams’ trial counsel, Nicholas Panarella, closed by emphasizing the defendant’s youth at the time of the murder and by urging the jury to find that age was a mitigating factor in the offense. He then asked that they consider any residual doubt remaining from the guilt phase and argued that a sentence of life imprisonment was sufficiently severe, for it would subject Williams to “all of the brutalities that are associated with prison life.” Panarella concluded by pleading for mercy. His plea was rejected. The jury found two aggravating circumstances, namely (1) that the murder occurred during commission of a felony (robbery), 42 Pa. Cons.Stat. § 9711(d)(6), and (2) that Williams had a significant history of felony convictions involving the use or threat of violence, 42 Pa. Cons.Stat. § 9711(d)(9). The jury found that there were no mitigating circumstances present in the case. They returned a sentence of death. II Williams has been contesting the jury’s death sentence almost from the moment it was announced on February 4, 1986. Shortly after trial, he dismissed Panarella and obtained new counsel, Norris Gelman. Gelman promptly filed a motion for a new trial on ineffective assistance of counsel grounds. On April 24 and July 1, 1987, the trial court held hearings on the motion during which Panarella was called to the stand to provide testimony on his mitigation strategy. He indicated that his central focus was Williams’ youth, which he believed to be the mitigating factor most applicable under § 9711 of the Pennsylvania Consolidated Statutes. Panarella also explained that Williams provided him little, if any, assistance, which frustrated efforts to present a strong cadre of character witnesses on the defendant’s behalf. Finally, when asked why he did not proffer evidence that Williams was psychologically damaged, Panarella was frank: My own personal observations of Mr. Williams were and are that he is a very cold, calculating person. I did not diseern any area where there was any doubt in my mind or that would have caused me to consider the fact that he was either not qualified or incapable of standing trial or facing punishment. At the conclusion of the hearing on July 1, 1987, Williams’ motion for a new trial was denied. The trial court thereafter sentenced him to death on the first degree murder conviction. On February 8, 1990, the Pennsylvania Supreme Court affirmed the trial court’s judgment and conviction. See Commonwealth v. Williams (Williams I), 524 Pa. 218, 570 A.2d 75 (1990). Williams did not petition for certiorari in the United States Supreme Court. He did, however, timely file a pro se petition for relief under Pennsylvania’s Post Conviction Relief Act (PCRA), 42 Pa. Cons.Stat. § 9541 et seq. New counsel was appointed and filed an amended petition raising twenty-three separate claims for relief. Among them, Williams argued that the Commonwealth exercised its peremptory strikes in a racially discriminatory manner, in violation of Batson v. Kentucky, 476 U.S. 79, 106 S.Ct. 1712, 90 L.Ed.2d 69 (1986), and that Panarella provided constitutionally ineffective assistance during the trial’s penalty phase. The Court of Common Pleas denied relief on October 20, 1998, and on December 22, 2004, the Pennsylvania Supreme Court affirmed over the dissent of two justices. See Commonwealth v. Williams (Williams II), 581 Pa. 57, 863 A.2d 505 (2004). In July of 2005, Williams filed a timely petition for a writ of habeas corpus in the United States District Court for the Eastern District of Pennsylvania. He therein raised a total of twenty-one claims, most of them not pertinent to the instant appeal. The District Court denied the petition in a thorough memorandum dated May 8, 2007, but granted Williams a certificate of appealability on two issues: (1) whether the Commonwealth exercised its peremptory strikes in a racially discriminatory manner, and (2) whether trial counsel was constitutionally ineffective during the penalty phase. We later granted Williams’ motion to expand the certificate of appealability, permitting him to contest the constitutionality of the trial court’s jury instructions on accomplice liability. We address each of these issues in turn. Ill The District Court had jurisdiction under 28 U.S.C. §§ 2241 and 2254. We have jurisdiction pursuant to 28 U.S.C. §§ 1291 and 2253. The District Court did not conduct an evidentiary hearing in this case, instead limiting itself to the evidence contained in the state court record. Our review of the District Court’s legal conclusions is therefore plenary, and we evaluate “ ‘the state courts’ determinations under the same standard that the District Court was required to apply.’ ” Lewis v. Horn, 581 F.3d 92, 100 (3d Cir.2009) (quoting Thomas v. Horn, 570 F.3d 105, 113 (3d Cir.2009)). Review of the instant petition is governed by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. § 2241 et seq. Hardcastle v. Horn, 368 F.3d 246, 254 (3d Cir.2004) (petitions filed after April 1996 subject to AEDPA standards). For inmates such as Williams, who are incarcerated by the state, AEDPA prohibits federal court relief on claims which have not been presented to the state’s tribunals. See 28 U.S.C. § 2254(b). If a petitioner’s claim has been adjudicated on the merits in state court, habeas relief is precluded unless the state court’s decision was (1) “contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States”; or (2) “was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.” § 2254(d). Thus, AEDPA erects “ ‘a substantially higher threshold’ for obtaining relief than de novo review.” Renico v. Lett, — U.S. -, 130 S.Ct. 1855, 1862, 176 L.Ed.2d 678 (2010) (quoting Schriro v. Landrigan, 550 U.S. 465, 473, 127 S.Ct. 1933, 167 L.Ed.2d 836 (2007)). “[A] federal habeas court may not issue the writ simply because that court concludes in its independent judgment that the relevant state-court decision applied clearly established federal law erroneously or incorrectly,” Williams v. Taylor, 529 U.S. 362, 411, 120 S.Ct. 1495, 146 L.Ed.2d 389 (2000); relief instead requires a determination that the state court’s application was unreasonable, Renico, — U.S.-, 130 S.Ct. at 1862. In addition, AEDPA endows a state tribunal’s findings of fact with a “presumption of correctness,” and this presumption extends “to the factual determinations of state trial and appellate courts.” Duncan v. Morton, 256 F.3d 189, 196 (3d Cir.2001) (citing 28 U.S.C. § 2254(e)(1) and Dickerson v. Vaughn, 90 F.3d 87, 90 (3d Cir.1996)). To overcome the presumption, a habeas petitioner must proffer clear and convincing evidence to show that a factual determination is “objectively unreasonable in light of the evidence presented in the state-court proceeding.” Miller-El v. Cockrell, 537 U.S. 322, 340, 123 S.Ct. 1029, 154 L.Ed.2d 931 (2003). Our review proceeds under this AEDPA rubric. A Batson Claim Williams, who is an African American male, argues that the Commonwealth’s use of peremptory challenges during jury selection violated Batson v. Kentucky, 476 U.S. 79, 106 S.Ct. 1712, 90 L.Ed.2d 69 (1986) . In Batson, the Supreme Court held that deliberate or purposeful exclusion of African Americans from jury service violates the Equal Protection Clause. Batson, 476 U.S. at 84, 106 S.Ct. 1712. The decision set forth a three-step procedure for evaluating claims of discrimination in the jury selection process: First, a defendant must make a prima facie showing that a peremptory challenge has been exercised on the basis of race. Second, if that showing has been made, the prosecution must offer a race-neutral basis for striking the juror in question. Third, in light of the parties’ submissions, the trial court must determine whether the defendant has shown purposeful discrimination. Miller-El, 537 U.S. at 328-29 [123 S.Ct. 1029] (discussing three-step inquiry and citing Batson, 476 U.S. at 96-98 [106 S.Ct. 1712]). Batson was handed down in April 1986 — four months after the jury was empaneled to hear the Norwood murder trial. However, because Williams’ conviction was pending on direct review at the time Bat-son was decided, its holding applies retroactively to jury selection in the Norwood case. See Griffith v. Kentucky, 479 U.S. 314, 328 [107 S.Ct. 708, 93 L.Ed.2d 649] (1987) . We thus begin our review of Williams’ Batson claim by reconstructing the voir dire, which commenced on January 6,1986. Each party was afforded a total of twenty peremptory challenges. The Commonwealth exercised its first two strikes on African American venirepersons; this prompted Panarella to object and led to the following exchange: MR. PANARELLA: Your Honor, I’m not sure of the case but there was a recent case which dealt with an attempt by the State or the Commonwealth to systematically exclude blacks from the jury. I think it would be appropriate if we were to ask the Commonwealth on what basis they exercised the peremptory challenge. THE COURT: Anything you want to say? [PROSECUTOR]: No, your Honor, and I might point out that the defense has exercised its peremptory challenges. I believe that this may be only the first challenge that I have exercised at all. THE COURT: So far, the defense has challenged peremptorily two persons who, incidentally, both of whom were white. The Commonwealth has peremptorily challenged two persons who, incidentally, both of whom are black. The Court is very cognizant of the law in that area; however, at this point, I can see nothing that suggests that the peremptory challenges are being based on race alone. I’m not going to ask the Commonwealth to set forth the reason; however, I will ask Miss Foulkes if the peremptory challenges are being based on race alone? [PROSECUTOR]: Absolutely not, your Honor. I might suggest they are not being based on race at all. THE COURT: Thank you very much. The record will reflect your objection. The Commonwealth then used its next two peremptory challenges to strike two more African American members of the venire. Panarella objected a second time, stating, “I have raised an objection with respect to how she has raised her peremptory chailenges.” The trial judge then stated, With respect to your objection concerning the use of peremptory challenges, that is your right and if there’s anything you want to say further regarding that, you are free to say it.... You made your position plain the last time, Miss Foulkes, and I continue to accept that you are challenging people without respect to race but with respect to what other determinations you choose to make which you believe to be right under the law. In response, the prosecutor, Andrea Foulkes, simply noted that “the record will speak for itself.” The Commonwealth thereafter struck ten additional African American venirepersons. Panarella did not object to the exercise of any of these strikes. In sum, fourteen of the sixteen peremptory challenges exercised by the prosecutor were utilized to dismiss African Americans. She struck fourteen of the nineteen African American venire members that she had the opportunity to peremptorily dismiss. In contrast, Foulkes struck only two of the twenty-one white individuals she had the opportunity to peremptorily excuse. At the conclusion of voir dire, the trial court empaneled a jury composed of five black jurors and seven white jurors. Williams did not advance a Batson challenge on direct appeal. He did, however, raise the issue in his PCRA petition. Williams’ petition also asserted that his trial counsel was ineffective “for failing to insist that [the prosecutor] provide race neutral reasons for her challenges,” and that appellate counsel was ineffective for neglecting to raise a Batson claim on direct appeal. In April 1998, twelve years after jury selection in the Norwood murder trial, the PCRA court held an evidentiary hearing on the issue. At the outset of the hearing, the PCRA court provided Williams with several pages of notes that the judge had taken during voir dire. The court summarized its notes for the record: There were 111 prospective jurors called. That’s [the] total composition of the jury panel from which the jury was selected. Of those 111, 68 were white and 43 were black. The composition of the jury, the 12 principal jurors, was 7 white and 5 black. Total perempts— neither side used the full quota of 20 perempts. The total perempts were 35, 18 of which were applied to white prospective jurors, 17 to black prospective jurors. The Commonwealth utilized 16 peremptory challenges, 2 of white jurors, 14 of black jurors. The defense used 19 peremptory challenges, 16 of white jurors, 3 of black jurors. Williams then called Foulkes to the stand. She provided an explanation for each of her peremptory challenges and stated that she “categorically did not” strike any venireperson on the basis of race. Foulkes also testified that in order to prepare for the PCRA hearing, she reviewed a transcript of voir dire as well as the handwritten notes that she took during jury selection. After reviewing both the transcript and the notes, Foulkes created a one-page document that summarized, to the best of her recollection, the rationale behind each peremptory challenge. She used this summary to aid her PCRA testimony, though she acknowledged that she was unable to remember each of her reasons for exercising a strike. Williams’ counsel was provided a copy of the one-page summary and used it to question Foulkes during the hearing. In addition, Williams moved for production of the handwritten notes that Foulkes took contemporaneous with voir dire. He argued that production of the notes was necessary so that he could discover whether Foulkes recorded the race of each potential juror, and to check the veracity of her testimony. The PCRA court reviewed the contemporaneous notes in camera and thereafter denied Williams’ request. According to the court, the notes contained nothing [ ] that needs to be supplied to defense counsel or to be made part of the record. Miss Foulkes was called by the defense and testified fully and completely using, in a very limited way, the notes that are the subject of this inquiry to refresh her recollection. Under the circumstances, ... no further discovery is warranted. In a written order dated January 13, 1999, the PCRA court denied Williams’ Batson challenge, concluding that he had failed to make out a prima facie case at step one of Batson’s three-step analytical framework. Williams appealed, and the Pennsylvania Supreme Court ruled that the Batson claim was waived because it was not presented on direct appeal. It then turned to the derivative ineffective assistance of counsel claims. To assess these claims, the court looked to the underlying Batson challenge. Under Pennsylvania law, as set forth in Commonwealth v. Uderra, 580 Pa. 492, 862 A.2d 74 (2004), the failure to raise a Batson objection during voir dire deprives a petitioner of Batson’s three-step burden-shifting procedure. A petitioner so deprived must instead shoulder the burden to prove actual, purposeful discrimination by a preponderance of the evidence. The Pennsylvania Supreme Court found that Williams’ “trial counsel did not raise a Batson objection during voir dire,” and thus the Uderra rule applied. Williams II, 863 A.2d at 514. It then determined that Williams had not marshaled evidence sufficient to prove actual, purposeful discrimination. Id. at 515. In other words, the Pennsylvania Supreme Court held that the underlying Batson claim was without merit. Because the Batson claim was meritless, Williams’ trial and appellate counsel could not have been ineffective for failing to raise it. Finally, the court rejected Williams’ contention that he was entitled to production of Foulkes’ contemporaneous handwritten notes, concluding that he had “fail[ed] to demonstrate exceptional circumstances existed which required production of the actual notes.” Id. at 515 n. 10 (citing 42 Pa. Cons.Stat. § 9545(d)(2) (“No discovery, at any stage of proceedings under this sub-chapter, shall be permitted except upon leave of court with a showing of exceptional circumstances.”)). Williams’ federal habeas petition presented both his Batson claim and the derivative claims of ineffective assistance of counsel. He also requested an evidentiary hearing and an opportunity to discover Foulkes’ handwritten notes. The District Court denied Williams’ request for discovery, addressed the Batson claim on its merits, and held that the PCRA court unreasonably applied clearly - established federal law when it concluded that Williams had not made a prima facie showing of racial discrimination at step one of the Batson analysis. Even so, the District Court found that the Commonwealth proffered clear and reasonably specific race-neutral reasons for its peremptory strikes and that, in the face of such a proffer, Williams was unable to show purposeful discrimination in the Commonwealth’s selection of jurors. Therefore, the Court held that Williams’ Batson challenge was without merit. Williams contends that the District Court erred in three respects: first, it should have compelled production of the handwritten notes; second, it should have conducted an evidentiary hearing to allow Williams to question Foulkes regarding the content of the notes; and third, it should have concluded that the Commonwealth’s use of peremptory challenges contravened Batson. The Commonwealth offers rejoinders to each of these arguments and identifies two alleged errors of its own. Specifically, the Commonwealth claims that (1) the Pennsylvania Supreme Court’s application of the rule announced in Commonwealth v. Uderra, 580 Pa. 492, 862 A.2d 74 (2004), is reasonable and governs the analysis of Williams’ Batson challenge; and (2) even if the Uderra rule does not apply, the PCRA court reasonably concluded that Williams failed to make a prima facie showing of purposeful discrimination. We address each of these competing claims below. 1 Production of Prosecutor’s Notes & Evidentiary Hearing Williams argues that the PCRA court denied him a full and fair opportunity to litigate his Batson claim when it rejected his request to produce Foulkes’ contemporaneous voir dire notes. He does not ask us to review the state court’s evidentiary decision, but instead argues that under federal law, he is entitled to production of the notes so that he may pursue his § 2254 claims in federal court. Williams petitioned the District Court for production of the notes and for an evidentiary hearing in which to probe the rationale underlying the Commonwealth’s exercise of peremptory challenges. The District Court denied both requests. Williams claims that this ruling was in error. Discovery in § 2254 litigation proceeds according to Rule 6 of the Rules Governing § 2254 Cases. That provision states, “A judge may, for good cause, authorize a party to conduct discovery under the Federal Rules of Civil Procedure and may limit the extent of discovery.” Accordingly, habeas petitioners are entitled to discovery only upon a showing of “good cause,” and even then, the scope of discovery is subject to a district court’s sound discretion. See Harris v. Nelson, 394 U.S. 286, 299-300, 89 S.Ct. 1082, 22 L.Ed.2d 281 (1969) (discussing pre-Rule 6 discovery standard); Bracy v. Gramley, 520 U.S. 899, 909, 117 S.Ct. 1793, 138 L.Ed.2d 97 (1997) (explaining that Rule 6 was meant to be consistent with Harris); see also Deputy v. Taylor, 19 F.3d 1485, 1493 (3d Cir.1994) (“A district court sitting in a habeas case retains the discretion to permit additional discovery if the petitioner presents ‘good cause’ to do so.”). A habeas petitioner may satisfy the “good cause” standard by setting forth specific factual allegations which, if fully developed, would entitle him or her to the writ. See Harris, 394 U.S. at 300, 89 S.Ct. 1082; see also Lave v. Dretke, 416 F.3d 372, 380 (5th Cir.2005). The burden rests upon the petitioner to demonstrate that the sought-after information is pertinent and that there is good cause for its production. R. 6(b) R. Gov. § 2254 Cases; Williams v. Bagley, 380 F.3d 932, 974 (6th Cir.2004); Murphy v. Johnson, 205 F.3d 809, 814-15 (5th Cir.2000). We review the District Court’s denial of a discovery request for abuse of discretion. Smith v. Mahoney, 611 F.3d 978, 997 (9th Cir.2010); Teti v. Bender, 507 F.3d 50, 60 (1st Cir.2007); Williams, 380 F.3d at 974; United States v. Roane, 378 F.3d 382, 403 (4th Cir.2004); Newton v. Kemna, 354 F.3d 776, 783 (8th Cir.2004); see also Bracy, 520 U.S. at 909, 117 S.Ct. 1793. A district court abuses its discretion when discovery is “ ‘essential for the habeas petitioner to develop fully his underlying claim.’” Mahoney, 611 F.3d at 997 (quoting Dung The Pham v. Terhune, 400 F.3d 740, 743 (9th Cir.2005)). The PCRA court afforded Williams considerable latitude to develop the facts underlying his Batson challenge during collateral proceedings. Williams was granted a six-day evidentiary hearing; he called Foulkes to the stand and conducted an extensive examination; he was provided with a one-page document, created by Foulkes, summarizing her concerns with each of the venire members that she struck; and he was given several pages of the trial court’s voir dire-related notes. What is more, although Williams was not supplied with Foulkes’ handwritten voir dire notes, he was expressly permitted to question the prosecutor regarding that which she recorded in those notes. On direct examination, Foulkes described the content of her handwritten notes as follows: I took notes with respect to each individual prospective venire person as they came up and as they spoke. My process of thinking requires contemporaneously writing. It’s just something that I do. And what I wrote down were principally what it was that they said. It’s that simple. If there was something overtly extraordinary about the witness that I observed, I would also write that down, but not always, and that was not always necessary, and whatever I didn’t write down would also be reflected on the record. Foulkes later explained that she “mostly wrote down things like location, age, whether they had children, where they worked, the things that we ask in voir dire routinely.” Thus, according to Foulkes, much of what she recorded in her notes was also reflected in the record; in other words, the information was readily available for Williams to use as he mounted his collateral attack. When Williams queried whether Foulkes recorded each prospective juror’s race, the prosecutor replied that she generally did not, stating No, I don’t believe I did. I would record both black and white jurors in the couple of occasions that I recorded race at all. I recorded them more or less equally for black and white jurors, and I don’t think I did it beyond the first few prospective jurors, and then I just stopped doing it. It wasn’t necessary, certainly, to do it. Of course, the PCRA judge heard Foulkes’ testimony and her description of the notes’ contents. When he later examined the notes in camera, he was aware of the prosecutor’s representations, as well as Williams’ specific concerns regarding the veracity of those representations. Yet, the court stated on the record that it found “nothing [in the notes] that needs to be supplied to defense counsel or to be made part of the record.” Furthermore, the court characterized Foulkes’ testimony regarding her notes as “full” and “complete,” and ruled that “no further discovery is warranted.” Williams now essentially asks that we disbelieve the PCRA court, yet he presents us with no fact-based reason to do so. Instead, he argues that the notes are imperative so that he may inquire into the prosecutor’s state of mind. His argument proceeds as if he has never had such an opportunity. But Williams has subjected Foulkes to cross examination on precisely this point. He has also discovered a summary compilation of the motives underlying her strikes. The PCRA judge compared this summary, in camera, to Foulkes’ raw notes, and pronounced it a “full” and “complete” disclosure. Thus, Williams has already been afforded significant opportunity to discover the prosecutor’s state of mind; he fails to set forth, in a colorable manner, exactly what he lacks. Ultimately, Williams’ request amounts to an entreaty to engage in a fishing expedition. The law is clear, however, that such speculative discovery requests should be rejected. See Murphy, 205 F.3d at 814 (“Simply put, Rule 6 does not authorize fishing expeditions.”); see also Mayberry v. Petsock, 821 F.2d 179, 185 (3d Cir.1987). The District Court reviewed the record of collateral proceedings, remarked upon the significance of both the PCRA court’s in camera review and subsequent characterization of the notes, and ruled that Williams “received all the information he is constitutionally entitled to in order to proceed with his Batson claim.” The District Court did not abuse its discretion in reaching this conclusion. See Mahoney, 611 F.3d at 997 (stating that a district court abuses its discretion when it denies discovery that is essential to development of the petitioner’s claim). In addition, the District Court did not abuse its discretion by denying Williams’ motion for an evidentiary hearing. District courts have discretion to grant such hearings under § 2254(e)(2). Palmer v. Hendricks, 592 F.3d 386, 393 (3d Cir.2010); Campbell v. Vaughn, 209 F.3d 280, 287 (3d Cir.2000). We have set forth two considerations to guide a district court when confronted with such requests: first, it “should determine whether the petition presents a prima facie showing which, if proven, would enable the petitioner to prevail on the merits of the asserted claim,” and second, even if the petitioner satisfies this first criterion, the court “may decline to convene an evidentiary hearing if the factual allegations are ‘contravened by the existing record.’ ” Palmer, 592 F.3d at 393 (quoting Schriro, 550 U.S. at 474, 127 S.Ct. 1933); see also Morris v. Beard, 633 F.3d 185, 196 (3d Cir.2011) (“ ‘[I]f the record refutes the applicant’s factual allegations or otherwise precludes habeas relief,’ no evidentiary hearing is required.” (quoting Schriro, 550 U.S. at 474, 127 S.Ct. 1933)). Moreover, we have stressed that “courts [should] focus on whether a new evidentiary hearing would be meaningful, in that a new hearing would have the potential to advance the petitioner’s claim.” Campbell, 209 F.3d at 287. The District Court held that an evidentiary hearing would not advance Williams’ Batson inquiry. Williams was afforded a full and complete hearing in the PCRA court. He was provided with the trial court’s voir dire notes, as well as a document summarizing the motivation for each of the Commonwealth’s peremptory strikes. The prosecutor appeared for several hours of testimony, almost all of which centered upon her voir dire strategy and state of mind. She proffered an explanation for each of her challenges and supported most of these explanations by reference to the record. The racial composition of the venire and jury was clearly established. In short, the PCRA proceeding was comprehensive. Williams identifies no potential facts which a second evidentiary hearing is likely to unearth. The District Court quite accurately observed that “[n]o additional, relevant information would be gained from a federal hearing that cannot be gleaned from the state court record.” We agree. See Morris, 633 F.3d at 197 (explaining that an evidentiary hearing is warranted only if there are “critical issues of material fact” that remain unresolved). The District Court’s rejection of Williams’ discovery requests will be affirmed. 2 Application of the Uderra Rule On collateral appeal, the Pennsylvania Supreme Court determined that Williams waived his Batson claim because, as a matter of fact, “trial counsel did not raise a Batson objection during voir dire.” Williams II, 863 A.2d at 514. This was an unreasonable determination of facts in light of the evidence presented in the state court proceeding. The trial record is plain — and both parties agree — that Williams objected after the Commonwealth used its second peremptory challenge to dismiss an African American venireperson. Williams objected a second time after Foulkes exercised her fourth strike. Thus, the Pennsylvania Supreme Court’s fact-finding is clearly contradicted by the record. As a result of its mistake of fact, the Court did not address the Batson claim on its merits. The Pennsylvania Supreme Court did, however, indirectly address the Batson claim through its ineffective assistance inquiry. Specifically, Williams argued that trial counsel was ineffective for failing to insist that the Commonwealth provide race-neutral reasons for its challenges, and that appellate counsel was ineffective for neglecting to raise a Batson challenge on direct appeal. To assess the ineffective assistance claims, the Supreme Court queried whether Williams’ underlying Batson challenge was meritorious. It ultimately answered in the negative after applying its then-recent precedent, Commonwealth v. Uderra, 580 Pa. 492, 862 A.2d 74 (2004). Uderra held that when a post-conviction petitioner fails to raise an adequate Batson challenge at trial, he or she is not entitled to rely upon Batson’s burden-shifting framework in a collateral attack; rather, the petitioner must prove actual, purposeful discrimination by a preponderance of the evidence. Uderra, 862 A.2d at 86-87. In Williams’ case, the Pennsylvania Supreme Court held that the evidence did not meet the threshold mandated by Uderra. The court thus determined that the underlying Batson challenge lacked merit and, accordingly, rejected both ineffective assistance claims. Williams II, 863 A.2d at 514-15. Neither ineffective assistance claim is before us today. The Commonwealth argues that the Pennsylvania Supreme Court’s application of the Uderra rule is reasonable and must therefore guide our inquiry into the merits of Williams’ Batson challenge. In other words, the Commonwealth argues that we should not apply the three-step Batson framework, but should instead simply ask whether Williams proved racial discrimination by a preponderance of the evidence. We disagree. As explained above, the Pennsylvania Supreme Court determined that Williams waived his Batson claim; thus, it did not apply Uderra to the claim. In fact, it did not address the claim at all. See Laird v. Horn, 414 F.3d 419, 424 (3d Cir.2005) (critiquing contention that a state court implicitly addresses the merits of a claim when it rules on a derivative ineffective assistance of counsel claim). What is more, the Pennsylvania Supreme Court’s waiver holding is premised on an unreasonable determination of facts, namely: the faulty finding that Williams failed to raise a Batson objection during voir dire. Given these circumstances, we need not assess the appropriateness of the Uderra rule, nor will we express an opinion on whether it represents an unreasonable application of Batson. We now turn to the merits of this equal protection challenge. 3 Batson Merits The PCRA court denied Williams’ Batson claim on the merits: it held that there was insufficient evidence from which to infer that the Commonwealth exercised its peremptory challenges in a racially discriminatory manner. As noted above, the Pennsylvania Supreme Court did not address this substantive determination, but instead resolved Williams’ Batson claim on procedural grounds. The Supreme Court’s procedural resolution is the only decision entitled to preclusive effect. See Thomas, 570 F.3d at 115. Thus, for purposes of AEDPA, the Pennsylvania state courts have not adjudicated the Batson claim on the merits. See id. at 114-15; see also Lewis, 581 F.3d at 100 (explaining that when a state court’s final resolution of a claim is based on procedural grounds, that claim has not been “adjudicated on the merits” for purposes of § 2254(d)). No AEDPA deference is due by this Court. Lewis, 581 F.3d at 100. A Batson challenge presents a mixed question of law and fact on federal habeas review. Hardcastle, 368 F.3d at 254; Holloway v. Horn, 355 F.3d 707, 719 (3d Cir. 2004). When AEDPA deference does not apply, we review a mixed question of law and fact de novo. Lewis, 581 F.3d at 100. However, any of the state courts’ pure factual determinations, whether explicit or implicit, retain the presumption of correctness mandated by AEDPA. See id.; see also § 2254(e)(1); Simmons v. Beard, 590 F.3d 223, 231 (3d Cir.2009). Batson announced a three-step burden-shifting framework for judges to employ in order to determine whether racial discrimination is at work in jury selection. That procedure, which we have set forth above, requires a defendant to make out a prima facie case of purposeful discrimination before the prosecutor must articulate race-neutral justifications for her strikes. Miller-El, 537 U.S. at 328, 123 S.Ct. 1029 (citing Batson, 476 U.S. at 96-98, 106 S.Ct. 1712). After the parties have satisfied their respective burdens of production in these first two steps, the defendant must prove purposeful discrimination by a preponderance of the evidence. See id. at 328-29, 123 S.Ct. 1029 (citing Batson, 476 U.S. at 98,106 S.Ct. 1712). Establishment of a prima facie case requires the defendant to show that “the totality of the relevant facts gives rise to an inference of discriminatory purpose.” Johnson v. California, 545 U.S. 162, 168, 125 S.Ct. 2410, 162 L.Ed.2d 129 (2005) (quoting Batson, 476 U.S. at 93-94, 106 S.Ct. 1712). This step is not intended to be particularly onerous, and “the defendant is entitled to rely on the fact ... that peremptory challenges constitute a jury selection practice that permits those to discriminate who are of a mind to discriminate.” Abur-Jamal v. Horn, 520 F.3d 272, 288 (3d Cir.2008) (quoting Batson, 476 U.S. at 96, 106 S.Ct. 1712). That said, we have emphasized that “peremptory strikes are presumptively valid” and “need not be supported by any reason” so long as they are not “exercised on an unconstitutional basis, such as race or gender.” United States v. Dejesus, 347 F.3d 500, 505 (3d Cir.2003). The Supreme Court has identified at least two examples of circumstances relevant to step one’s totality inquiry. First, the defendant may proffer evidence that the government exercised a “ ‘pattern’ of strikes against black jurors included in the particular venire, [which] might [then] give rise to an inference of discrimination.” Batson, 476 U.S. at 97, 106 S.Ct. 1712. Second, “the prosecutor’s questions and statements during voir dire examination and in exercising his challenges may support or refute an inference of discriminatory purpose.” Id. In the instant matter, the venire was 39% African American. The Commonwealth exercised a total of sixteen peremptory challenges; fourteen of those were used to remove African American members of the venire. Thus, the prosecutor struck African Americans at a rate of 87.5%, but struck white venirepersons at a rate of 12.5%. The District Court called this pattern “stark” and held that these statistics alone were sufficient to make out a prima facie case. That ruling is consistent with our precedents. Statistical evidence may be sufficient by itself to make out a prima facie case of racial discrimination. See, e.g., Jones v. Ryan, 987 F.2d 960, 971 (3d Cir. 1993); Overton v. Newton, 295 F.3d 270, 278 & n. 9 (2d Cir.2002) (citing cases and stating “statistics, alone and without more, can, in appropriate circumstances, be sufficient to establish the requisite prima facie showing under Batson ”). In Holloway v. Horn, we had “little difficulty” finding a prima facie case when the prosecutor used eleven of twelve strikes to remove African American venirepersons. 355 F.3d at 722. Similarly, we found a prima facie showing in Brinson v. Vaughn, where the Commonwealth used thirteen of its fourteen strikes to remove African Americans. 398 F.3d 225, 234-35 (3d Cir.2005). Additionally, our decision in Hardcastle v. Horn strongly implies that a prosecutor who removes twelve of fourteen African American venire members exhibits a pattern of strikes sufficient to raise an improper inference. See 368 F.3d at 256. In each of these decisions, however, we were unable to fully reconstruct the racial composition of the venire. Reconstruction of the venire often provides crucial context to a prosecutor’s strike rate. See Abu-Jamal, 520 F.3d at 291-92. For example, a strike rate of 90% looks less stark when the venire is 90% African American. When the record does not illuminate the composition of the venire, there may be insufficient evidence with which to mount a successful collateral attack. Indeed, we rejected the petitioner’s challenge in Aim-Jamal when he established that ten of the prosecutor’s fifteen peremptory strikes were used to remove African Americans, but was unable to reconstruct the composition of the venire. See id. at 291-92. What is telling about Holloway, Brinson, and Hardcastle — in contrast to AbuJamal — is that the pattern of strikes in these cases was sufficient to satisfy the prima facie threshold even without evidence of the venire’s racial makeup. In each case, the strike rate exceeded 85%, whereas the rate in Abu-Jamal was 66.7%. Here, the strike rate also exceeded 85%; consistent with Holloway, Brinson, and Hardcastle, we find that evidence of the strike rate alone satisfies Williams’ prima facie showing. After all, the Commonwealth exercised fourteen of its sixteen peremptory challenges on African Americans. In a venire that was less than 40% black, it is hardly a leap to conclude that a strike rate of 87.5% raises an inference of discrimination. Although the strike rate data is sufficient by itself to make a prima facie showing in this ease, we need not rely exclusively on the Commonwealth’s strike rate. Evidence contrasting the rate at which the prosecution accepts black and white jurors may also raise an inference of discrimination. In Bond v. Beard, 539 F.3d 256 (3d Cir.2008), the prosecutor accepted between 41% and 47% of the black venirepersons that he had the opportunity to strike; his acceptance rate for white members of the venire was 83%. We held that the disparity between these acceptance rates was sufficient to make out a prima facie case at step one of the Batson analysis. Bond, 539 F.3d at 270. In this case, Foulkes accepted five of the nineteen African Americans she had the opportunity to strike. Her acceptance rate was thus 26.3%. By contrast, she accepted nineteen of the twenty-one white venirepersons she had the opportunity to strike. Her acceptance rate for white venire members was therefore 90%. Under Bond, this disparity raises an inference of discrimination. In sum, Williams has proffered statistical evidence sufficient to suggest that the Commonwealth’s peremptory challenges were based upon an improper motive. We must therefore proceed to step two and three of the Batson inquiry. The government’s burden of production at step two is “relatively low,” Hardcastle, 368 F.3d at 257; “[u]nless a discriminatory intent is inherent in the prosecutor’s explanation, the reason offered will be deemed race neutral,” Purkett v. Elem, 514 U.S. 765, 768, 115 S.Ct. 1769, 131 L.Ed.2d 834 (1995) (per curiam) (quoting Hernandez v. New York, 500 U.S. 352, 360, 111 S.Ct. 1859, 114 L.Ed.2d 395 (1991)). At the PCRA hearing, Foulkes provided an explanation for each of her strikes. Williams does not contend that any of Foulkes’ reasons were facially illegitimate. Nonetheless, we have reviewed the record and conclude that the proffered reasons, some of which are discussed in more detail below, are facially race-neutral. The burden therefore rests upon Williams to prove that the explanations offered by Foulkes are not persuasive and are instead pretextual. See Miller-El, 537 U.S. at 338-39, 123 S.Ct. 1029 (stating that step three of the Batson framework centers upon “the persuasiveness of the prosecutor’s justification”). At step three of the Batson analysis, the petitioner must show that “it is more likely than not that the prosecutor struck at least one juror because of race.” Bond, 539 F.3d at 264. To determine whether the petitioner has carried his or her burden, the court must evaluate “all evidence introduced by each side (including all evidence introduced in the first and second steps) that tends to show that race was or was not the real reason” for each strike. Hardcastle, 368 F.3d at 259 (quoting Riley v. Taylor, 277 F.3d 261, 286 (3d Cir.2001) (en banc)); see also Snyder v. Louisiana, 552 U.S. 472, 478, 128 S.Ct. 1203, 170 L.Ed.2d 175 (2008) (explaining that “all of the circumstances that bear upon the issue of racial animosity must be consulted”). Step three ultimately focuses upon the prosecutor’s subjective motivation, which ideally includes an assessment of the demeanor and credibility of the various voir dire participants. See Snyder, 552 U.S. at 477, 128 S.Ct. 1203 (“Step three of the Batson inquiry involves an evaluation of the prosecutor’s credibility, and the best evidence [of discriminatory intent] often will be the demeanor of the attorney who exercises the challenges.” (alteration in original) (internal citations and quotation marks omitted)). To the extent that such assessments factor into the court’s final ruling, they must be accorded significant deference on appeal. See id. at 477, 128 S.Ct. 1203; Dejesus, 347 F.3d at 507. As we have stated, the PCRA court made no step-three findings. The parties nonetheless developed a significant record at the PCRA hearing and, while this is a very imperfect substitute for a trial judge’s findings of fact, it permits sufficient — ■ though hardly ideal — collateral review. In the District Court, Williams proceeded by method of comparing stricken members of the venire to individuals the Commonwealth deemed acceptable. We have previously authorized such an evaluative procedure, explaining, “A comparison between a stricken black juror and a sitting white juror is relevant to determining whether the prosecution’s asserted justification for striking the black juror is pretextual.” Riley, 277 F.3d at 282; Holloway, 355 F.3d at 724; see also Snyder, 552 U.S. at 479-86, 128 S.Ct. 1203 (performing comparative analysis); Miller-El v. Dretke, 545 U.S. 231, 241-52, 125 S.Ct. 2317, 162 L.Ed.2d 196 (2005) (finding Batson violation based in part on juror comparison). An explanation that appears race neutral at step two may betray an improper motive if it is invoked to strike African Americans but not other non-black venirepersons exhibiting the same characteristic. Williams focuses upon five stricken members of the venire, all of whom were African American. We will confine our comparative inquiry accordingly. Lucille Dozier. Ms. Dozier was asked whether she had any beliefs which would prevent her “from being able to impose the death penalty in an appropriate case.” She answered, “I would have to be absolutely certain, sure that this person really deserves that.” After the prosecutor rephrased the question, Dozier stated that she could impose the death penalty if appropriate. At the PCRA hearing, Foulkes testified that she struck Dozier on the basis of her initial hesitancy. Foulkes explained, “[I]t appeared to me from her answers [that it would be] very difficult for her to apply the law in this case.” Williams names two comparators, both of whom were white: Debra Pagano, seated as juror number seven, and Virginia Feo, who was accepted by the Commonwealth but stricken by the defense. When Foulkes asked Pagano whether she would have any difficulty imposing the death penalty in an appropriate case, Pagano answered, “No.” Feo was posed the same question and stated that although it would not be “easy,” she “did not think” she would have any difficulty imposing a penalty of death. Neither of these comparators expressed a sentiment close to that exhibited by Dozier; specifically, neither Pagano nor Feo required “absolute certainty” in order to recommend the death penalty. The comparative evidence thus fails to suggest that Foulkes’ reason for striking Ms. Dozier was pretext. Shawn Kimble. Mr. Kimble was employed as a purchasing agent, graduated from Central High School in west Philadelphia, and studied business at Drexel University. Foulkes observed that he was approximately the same age as Williams and, in her opinion, he exhibited a “hostile affect.” Foulkes testified that she struck Kimble due to concerns about his attitude, his age, and because Williams asked Kimble no questions during voir dire. Furthermore, Foulkes explained that none of these factors alone moved her to exercise a challenge; rather, it was the combination of concerns that together led to the strike. Because the PCRA court resolved the Batson claim at step one, it did not assess Foulkes’ reasons for striking Kimble and, consequently, made no finding with respect to Kimble’s alleged hostility. We cannot presume that the PCRA court credited Foulkes’ assertion that Kimble displayed a hostile affect. See Snyder, 552 U.S. at 479, 128 S.Ct. 1203 (declining to credit prosecutor’s justification that stricken venireperson was excessively nervous when the state court did not make an on-the-record determination regarding venireperson’s demeanor). As a result, we will not consider the prosecutor’s demeanor-based reason for striking Kimble and will instead focus upon Foulkes’ remaining justifications: age and the defendant’s decision not to question Kimble on voir dire. Williams attacks these rationales by proffering two comparators to whom Williams posed no questions during voir dire, and who were nonetheless accepted by the Commonwealth. These two individuals — Isabelle Edmonson and Robert Eberle- — do not constitute true comparators for purposes of our inquiry. Although Williams did not ask any questions of either Edmonson or Eberle, both were significantly older than the defendant. Therefore, neither can be said to exhibit the same characteristics as Kimble (age and lack of questioning). In a comparison analysis, it is insufficient to proffer venire members who lack one or more of the characteristics upon which the prosecutor exercised a strike. This is not to erect an unreasonable roadblock; rather, it ensures accuracy in an area often guided by guesswork and hunches. See DeJesus, 347 F.3d at 505 (explaining that a peremptory challenge “is usually based on educated guesses about probabilities based on the limited information available to an attorney about prospective jurors”). Because the focus in step three is to uncover a prosecutor’s subjective motivation, it is imperative to account for the complete combination of factors