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Name: Johnson v. California
Case #: Apr-64
Court: US Supreme Court
District USSup
Opinion Date: 06/13/2005
Subsequent History: x-cite 125 S.Ct. 2410
Summary

Petitioner was a black man, convicted of murdering a white child. At this trial, the prosecutor used three of his 12 peremptory challenges to remove the prospective black jurors, resulting in an all-white jury. Defense counsel objected that the strikes were based on race, but the trial judge did not ask the prosecutor to explain his reasons, finding that petitioner had failed to establish a prima facie case of purposeful discrimination. The judge said that although it was a close case, the prosecutor’s strikes could be justified by race-neutral reasons. The Court of Appeal reversed, and the California Supreme Court reinstated the conviction, finding that Wheeler’s “strong likelihood” standard is entirely consistent with Batson. The court acknowledged that the exclusion of all three black jurors looked suspicious, but deferred to the trial court’s ruling. The United States Supreme Court reversed, finding that California’s “more likely than not” standard is an inappropriate yardstick by which to measure the sufficiency of a prima facie case of purposeful discrimination. Batson does not permit California to require that the objector show that it is more likely than not that the other party’s challenges were based on impermissible group bias. It assumes that the trial court would have the benefit of all relevant circumstances, including the prosecutor’s explanation, before deciding whether the challenge was improperly motivated. The inference of discrimination which caused the trial judge to call it a close case and the California Supreme Court to acknowledge that it was suspicious, was sufficient to establish a prima facie case. J. Thomas dissented.