In this automatic appeal from a sentence of death, the Supreme Court dispatched the issues raised by appellant and affirmed the sentence. Among the errors argued, appellant claimed a Batson/Wheeler violation in that the trial court erred in finding no prima facie case showing discrimination as to the dismissal of minority jurors. Because the record was unclear as to the standard the court used, the Supreme Court independently review the record and determined that there was no error and that the peremptory challenges were neutral. The court also found that although there was juror misconduct as a juror had introduced biblical passages into the deliberation process, the error was not prejudicial as there was not a reasonable probability that the passages influenced the verdict to the detriment of the defendant.
Case Summaries