During voir dire, the trial court found that appellant made a prima facie showing of discrimination when the prosecutor excused the only two African-American jurors in the box. The prosecutor then offered incomprehensible reasons for his excusal of the jurors, which were too vague and general for the court to evaluate, (i.e. her “dress” the “way she took her seat,” and “her responses to questions.”) The trial court accepted the meaningless explanations without further investigation. The appellate court here reversed. The trial court did not satisfy its Batson/Wheeler obligations. Further inquiry would have provided descriptions from which the court could have evaluated in determining the genuineness of the proffered explanations.
Case Summaries