Supreme Court Reversal on Batson Grounds
Jeffrey Brooks was a student at Southern University in New Orleans. Allen Snyder was a Louisiana man on trial in a Louisiana court for the first degree murder of his wife, Mary. And Mr. Brooks was a member of Synder’s jury panel.
The prosecution and defense winnowed the 85 prospective jurors of the panel down to 36 through challenges for cause. Five of the remaining 36 prospective jurors were African-Americans, including Mr. Brooks. The prosecutor proceeded to eliminate the remaining African-American jurors through the use of peremptory strikes. In the case of Mr. Brooks, the prosecutor offered the alleged race-neutral reasons that Mr. Brooks allegedly looked “very nervous” during questioning, and that he was a student teacher and therefore allegedly might be more inclined to render a guilty verdict on a lesser charge so that he could return to his teaching duties.
The defense made an objection pursuant to Batson v. Kentucky, 476 U.S. 79, 106 S.Ct. 1712 (1986), which the trial court overruled. Snyder was convicted of first-degree murder and appealed alleging Batson error, however the Louisiana Supreme Court affirmed the conviction. The United States Supreme Court then granted cert in Snyder v. Louisiana, 128 S.Ct. 1203 (March 19, 2008).
The majority, led by Justice Alito, reiterated the test in Batson for adjudicating a claim that a peremptory strike on a juror 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[;] [s]econd, if that showing has been made, the prosecution must offer a race-neutral basis for striking the juror in question[;] [and] [t]hird, in light of the parties’ submissions, the trial court must determine whether the defendant has shown purposeful discrimination.”
Id. at 1207 (quoting Miller-El v. Dretke, 545 U.S. 231, 277, 125 S.Ct. 2317 (2005) (Thomas, J., dissenting); quoting Miller-El v. Cockrell, 537 U.S. 322, 328-329, 123 S.Ct. 1029 (2003)). The majority found that the trial court did not make any specific findings regarding Mr. Brooks’ alleged demeanor on the record, and rejected his alleged nervousness as a possible ground for upholding the strike. Id. at 1209. Furthermore, the Court found that Mr. Brooks’ student teaching obligations were a suspicious ground on which to uphold the strike, noting that no less than 50 members of the panel expressed concerns that jury service would interfere with work, school, family, or other obligations; that the dean of the university had told the Court that Mr. Brooks could make up his missed work; that, after hearing the dean’s statements, Mr. Brooks no longer seemed concerned about serving on the jury; and that even the prosecution anticipated that trial would be relatively brief. Id. at 1209-1211. It further noted that the prosecution had accepted white jurors with conflicting obligations at least as, or more, important as Mr. Brooks’, and cited several examples. Id. at 1210.
The majority held that the prosecution’s pretextual explanations supported an inference that the strike was motivated in substantial part by a discriminatory intent pursuant to Batson, and that the state had produced no evidence that the factor was not determinative in the strike. Id. at 1212. It then reversed the judgment of the Louisiana Supreme Court and remanded Snyder’s case. Id.
