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Batson v. Kentucky provides a three-step process for a trial court to use in adjudicating a claim that a peremptory challenge was based on race. 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; and third, in light of the parties' submissions, the trial court must determine whether the defendant has shown purposeful discrimination.
Eighty-five prospective jurors were questioned as members of a panel. Thirty-six of these survived challenges for cause; 5 of the 36 were black; and all 5 of the prospective black jurors were eliminated by the prosecution through the use of peremptory strikes. When defense counsel made a Batson objection concerning the strike of one black juror, a college senior who was attempting to fulfill his student-teaching obligation, the prosecution offered two race-neutral reasons for the strike: (1) the juror looked very nervous throughout the questioning; and (2) he was going to miss his student teaching class. The jury convicted Petitioner Allen Synder and sentenced him to death. Both on direct appeal and on remand in light of Miller-El v. Dretke, 545 U.S. 231, 125 S. Ct. 2317, 162 L. Ed. 2d 196, the Louisiana Supreme Court rejected petitioner's claim that the prosecution's peremptory strikes of certain prospective jurors, including that of the black juror, were based on race, in violation of Batson v. Kentucky, 476 U.S. 79, 106 S. Ct. 1712, 90 L. Ed. 2d 69. Certiorari was granted.
With respect to a particular black juror, did the prosecution exercise a peremptory strike on basis of race?
The Court held that the trial court committed clear error in overruling objection, by petitioner in state capital-murder case, that with respect to particular prospective juror who was black, prosecution had exercised peremptory strike on basis of race. The Court held that it could not presume that the trial judge credited the prosecutor's assertion that the juror was nervous. The student-teaching obligation reason failed even under a highly deferential standard of review because a university dean had told the court that the juror's missing up to a week would not cause a problem and the juror did not express any further concern about serving on the jury. The implausibility of the explanation was reinforced by the prosecutor's acceptance of white jurors who disclosed conflicting obligations that appeared to have been at least as serious. Accordingly, the judgment of the lower court was reversed and the case was remanded for further proceedings.