Snyder v. Louisiana
Supreme Court of the United States
December 4, 2007, Argued; March 19, 2008, Decided
[*474] [**1206] Justice Alito delivered the opinion of the Court.
Petitioner Allen Snyder was convicted of first-degree murder in a Louisiana court and was sentenced to death. He asks us to review a decision of the Louisiana Supreme Court rejecting his claim that the prosecution exercised some of its peremptory jury challenges based on race, in violation of Batson v. Kentucky, 476 U.S. 79, 106 S. Ct. 1712, 90 L. Ed. 2d 69 (1986). We hold that the trial court committed clear error in its ruling on a Batson objection, and we therefore reverse.
The crime for which petitioner was convicted occurred in August 1995. At that time, petitioner and his wife, Mary, had separated. On August 15, they discussed the possibility [****6] of reconciliation, and Mary agreed to meet with petitioner the next day. That night, Mary went on a date with Howard Wilson. During the evening, petitioner repeatedly attempted to page Mary, but she did not respond. At approximately 1:30 a.m. on August 16, Wilson drove up to the home of Mary's mother to drop Mary off. Petitioner was waiting at the scene armed with a knife. He opened the driver's side door of Wilson's car and repeatedly stabbed the occupants, [*475] killing Wilson and wounding Mary.
The State charged petitioner with first-degree murder and sought the death penalty based on the aggravating circumstance that petitioner had knowingly created a risk of death or great bodily harm to more than one person. See La. Code Crim. Proc. Ann., Art. 905.4(A)(4) (West Supp. 2008).
Voir dire began on Tuesday, August 27, 1996, and proceeded as follows. During the first phase, the trial court screened the panel to identify jurors who did not meet Louisiana's requirements for jury service or claimed that service on the jury or sequestration for the duration of the trial would result in extreme hardship. More than 50 prospective jurors reported that they had work, family, or other commitments that [****7] would interfere [***180] with jury service. In each of those instances, the nature of the conflicting commitments was explored, and some of these jurors were dismissed. App. 58-164. Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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552 U.S. 472 *; 128 S. Ct. 1203 **; 170 L. Ed. 2d 175 ***; 2008 U.S. LEXIS 2708 ****; 76 U.S.L.W. 4136; 21 Fla. L. Weekly Fed. S 116
ALLEN SNYDER, Petitioner v. LOUISIANA
Subsequent History: On remand at, Remanded by State v. Snyder, 982 So. 2d 763, 2008 La. LEXIS 1011 (La., Apr. 30, 2008)
Prior History: [****1] ON WRIT OF CERTIORARI TO THE SUPREME COURT OF LOUISIANA.
State v. Snyder, 942 So. 2d 484, 2006 La. LEXIS 2309 (La., Sept. 6, 2006)
Disposition: Reversed and remanded.
jurors, trial court, demeanor, missing, trial judge, proffered, reasons, credibility, teaching, nervous, discriminatory intent, peremptory challenge, defense counsel, questioned, plurality opinion, jury service, voir dire, first-degree, murder, phase, circumstances, obligations, lesser, defer, death penalty, race-neutral, nervousness, peremptory, semester, serving
Criminal Law & Procedure, Challenges to Jury Venire, Equal Protection Challenges, Race-Neutral Strikes, Tests for Equal Protection Violations, Appellate Review, Constitutional Law, Equal Protection, National Origin & Race, Equal Protection Rule, Burdens of Proof