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against a public officer, and instead involves only the denial of a motion in a criminal case.’ This transfer order established the rule of the case, and thus the trial court erred in finding that MacBeth's challenge to the traverse jury list constituted a petition for a writ of mandamus. See id. Moreover, the trial court's ruling that it lacked jurisdiction to hear MacBeth's challenge is further belied by the examples in Georgia case law, in which courts of limited jurisdiction have, in fact, heard similar challenges to jury arrays. See generally Ricks v. State, 221 Ga. 837, 838(2), 147 S.E.2d 431 (1966) (defendant challenged traverse jury list in a misdemeanor case brought against him in the City Court of Colquitt County); Kitchens v. State, 221 Ga. 839, 839(1), 147 S.E.2d 509 (1966) (same); Watson v. State, 261 Ga.App. 562, 565-566(3), 583 S.E.2d 228 (2003) (defendant challenged traverse jury list in a case brought against her in Clayton County State Court).” 2. Defendant’s challenge to the array was not premature, though apparently filed prior to the array being put to the defendant. “‘[I]n the absence of a timely trial court directive to the contrary, a challenge to the traverse jury array is timely filed any time before the voir dire begins.’ (Emphasis supplied.) Isaacs v. State, 259 Ga. 717, 721(3)(a), 386 S.E.2d 316 (1989).” Berghuis v. Smith, 559 U.S. 314, 130 S.Ct. 1382, 176 L.Ed.2d 249 (March 30, 2010). Reversing Sixth Circuit, Michigan Supreme Court decision finding that murder defendant Smith “ha[d] not shown … systematic exclusion” of black jurors did not “involv[e] an unreasonable application o[f] clearly established Federal law, as determined by the Supreme Court of the United States,” such as would authorize federal habeas relief. 1. Michigan court could find that defendant “ha[d] not established a prima facie violation of the Sixth Amendment fair-cross-section requirement.” “To establish a prima facie violation of the fair-cross-section requirement, this Court's pathmarking decision in Duren [ v. Missouri, 439 U.S. 357, 99 S.Ct. 664, 58 L.Ed.2d 579 (1979)] instructs, a defendant must prove that: (1) a group qualifying as ‘distinctive’ (2) is not fairly and reasonably represented in jury venires, and (3) ‘systematic exclusion’ in the jury- selection process accounts for the underrepresentation. 439 U.S., at 364, 99 S.Ct. 664.” Defendant contested county’s practice of assigning jurors first to lower, misdemeanor courts, remainder going to circuit court, where felonies are prosecuted. Defendant contended that minority jurors were thus “siphoned” from circuit court, but U.S. Supreme Court agrees with Michigan Supreme Court that defendant failed to prove “systematic exclusion” of minority jurors. Court here suggests ways defendant could have, but failed to, prove his case: “Evidence that African-Americans were underrepresented on the Circuit Court's venires in significantly higher percentages than on the Grand Rapids District Court's could have indicated that the assignment order made a critical difference. But, as the Michigan Supreme Court noted, Smith adduced no evidence to that effect. … Nor did Smith address whether Grand Rapids, which had the County's largest African-American population, ‘ha[d] more need for jurors per capita than [any other district in Kent County].’ … Furthermore, Smith did not endeavor to compare the African-American representation levels in Circuit Court venires with those in the Federal District Court venires for the same region.” 2. Sixth Circuit erred by concluding that underrepresentation must be measured by comparative disparity, as opposed to absolute disparity or standard deviation. “As the Michigan Supreme Court correctly observed, … neither Duren nor any other decision of this Court specifies the method or test courts must use to measure the representation of distinctive groups in jury pools.” Nor does the Court here express an opinion preferring any method, instead finding that Michigan’s consideration of all three measures was not unreasonable, contrary to Sixth Circuit’s insistence on using comparative disparity. 3. Defendant failed to prove that other practices resulted in systematic exclusion. “Smith's list includes the County's practice of excusing people who merely alleged hardship or simply failed to show up for jury service, its reliance on mail notices, its failure to follow up on nonresponses, its use of residential addresses at least 15 months old, and the refusal of Kent County police to enforce court orders for the appearance of prospective jurors. No ‘clearly established’ precedent of this Court supports Smith's claim that he can make out a prima facie case merely by pointing to a host of factors that, individually or in combination, might contribute to a group's underrepresentation.” “The Michigan Supreme Court was … far from ‘unreasonable,’ § 2254(d)(1), in concluding that Duren first and foremost required Smith himself to show that the underrepresentation complained of was ‘due to systematic exclusion.’ [Cit.] This Court, furthermore, has never ‘clearly established’ that jury-selection-process features of the kind on Smith's list can give rise to a fair-cross-section claim. In Taylor [ v. Louisiana, 419 U.S. 522, 95 S.Ct. 692, 42 L.Ed.2d 690 (1975)] , we ‘recognized broad discretion in the States’ to ‘prescribe relevant qualifications for their jurors and to provide reasonable exemptions.’ 419 U.S., at 537-538, 95 S.Ct. 692. And in Duren, the Court understood that hardship exemptions resembling those Smith assails might well ‘survive a fair-cross-section challenge,’ 439 U.S., at 370, 99 S.Ct. 664.” “We have also never ‘clearly’ decided, and have no need to consider here, whether the impact of social and economic factors can support a fair-cross-section claim.” Humphreys v. State, 287 Ga. 63, 694 S.E.2d 316 (March 15, 2010). Trial court properly denied motion to quash defendant’s capital murder indictment based on excusal of grand jurors. 1. Excusal of grand jurors by Cobb Superior jury administrator was authorized by local rule. USCR 1.2 permits local rules governing jury excusals. Local rules regarding jury excusals survived expiration of local rules under USCR 1.1 in 1994. 2. Grounds for excusals complied