Law School Case Brief
City of Seattle v. Erickson - 188 Wash. 2d 721, 398 P.3d 1124 (2017)
The peremptory strike of a juror who is the only member of a cognizable racial group constitutes a prima facie showing of racial discrimination requiring a full Batson analysis by the trial court.
In 2013, Matthew Erickson, a black man, was charged in Seattle Municipal Court with unlawful use of a weapon and resisting arrest. After voir dire, the city of Seattle (City) exercised a peremptory challenge against the only black juror on the jury panel. After the jury was empaneled and excused from the courthouse with the rest of the venire, Erickson objected to the peremptory challenge pursuant to Batson, claiming the strike was racially motivated. The municipal court found that there was no prima facie showing of racial discrimination and overruled Erickson's objection. The superior court affirmed the municipal court, finding that the circumstances surrounding the challenge did not raise any inference that the juror was struck because of his race.
Was there a prima facie showing of racial discrimination when the City struck the only black juror on the jury panel?
The Court held that the prosecutor's peremptory strike of the only black juror constituted a prima facie showing of racial motivation sufficient to trigger a full Batson analysis. The reviewing court adopts a bright-line rule that a trial court must recognize a prima facie case of discriminatory purpose when the sole member of a racially cognizable group was peremptorily struck from a jury. As such, the Court found it proper to remand the case for new trial.
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