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Name: People v. Arias (2024) 101 Cal.App.5th 1163
Case #: A164789
Court: CA Court of Appeal
District 1 DCA
Division: 1
Opinion Date: 05/10/2024

Where the record failed to support the trial court’s unexplained third-stage ruling that the peremptory challenge of a juror was not discriminatory, reversal was required. In a child molestation case, the defense made a Batson/Wheeler motion as to the prosecutor’s striking of a Black prospective juror. The trial court accepted the prosecutor’s reasons for the striking, and denied the motion. However, the prosecutor’s first reason was unsupported by the record, the second reason was “deeply troubling,” and the third reason was of apparently minor significance to the prosecutor. The trial court’s uncritical crediting of these reasons was unreasonable given the record of voir dire proceedings. Because the error was structural, the judgment was reversed.

The full opinion is available on the court’s website here: