Law School Case Brief
Barfield v. Orange Cty. - 911 F.2d 644 (11th Cir. 1990)
The equal protection clause, U.S. Const. amend. XIV, forbids a prosecutor to challenge potential jurors solely on account of their race or on the assumption that black jurors as a group will be unable impartially to consider the state's case against a black defendant. Once a defendant establishes a prima facie case that potential jurors have been struck on account of race, the burden shifts to the state to come forward with a racially-neutral explanation for the challenge. This rule also applies in civil cases.
Plaintiff corrections officer, Brenda L. Barfield, brought this civil rights action against defendant Lawson Lamar individually and in his official capacity as Sheriff of Orange County, Florida. The complaint included a variety of civil rights claims pursuant to 42 U.S.C. § 1981, 42 U.S.C. § 1983 and Title VII, 42 U.S.C. § 2000e et seq. Barfield had been employed by the Sheriff as a corrections officer. She alleged, among other things, that she was the victim of racial discrimination in connection with her employment by the Sheriff, that her employment was terminated by the Sheriff because of her race (she is black), and that this termination violated her due process rights under the Fourteenth Amendment. All claims except for the Title VII claim were tried to a jury; the Title VII claim was simultaneously tried to the court. The jury found for the Sheriff, after which the trial judge also found in favor of the Sheriff. Plaintiff Barfield sought review, arguing inter alia that the trial court erred in denying Batson v. Kentucky, 476 U.S. 79, 106 S. Ct. 1712, 90 L. Ed. 2d 69 (1986), challenge to the Sheriff's use of two of his peremptory challenges to excuse black persons on the venire. Second, she argues that the trial court erred in permitting the Sheriff to offer in evidence during the jury trial a report of the Equal Employment Opportunity Commission (EEOC) and a report of the Florida Unemployment Appeals Commission concerning their investigation of Barfield's complaints, including her complaint that her termination was discriminatory.
Did the plaintiff prove that her termination of her employment was racially motivated?
The Court upheld the ruling of the district court, holding that the use of two of defendant's three available peremptory challenges to strike the only two black persons called and seated was not error. The fact that a black school board employee was challenged while white school board employees were not challenged was certainly a circumstance properly considered, but the explanation was not legally insufficient as a matter of law. The fact that defendant did not challenge all school board employees did not compel a conclusion by the trial court that this challenge was racially motivated. The court also held that the trial court did not err in admitting Equal Employment Opportunity Commission determinations under Fed. R. Evid. 803(8)(C).
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