Reversal was required where the prosecutor excused two of the only African-American jurors, one because she was “from Inglewood,” and was childless, and the other because she had an “unfriendly demeanor.” Defense counsel had made a prima facie case of discriminatory exclusion, since there were only two African-American jurors who had been questioned, and other jurors with the same characteristics other than race had been retained. The burden then shifted to the prosecutor to present a race-neutral explanation of the challenge. The fact that the juror was “from Inglewood” was not a satisfactory explanation, since African-Americans comprise about half of the population of Inglewood. Since the prosecutor failed to demonstrate that the excluded jurors were not excluded due to group bias, reversal was required.
Case Summaries