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Name: Snyder v. Louisiana
Case #: 06-10119
Court: US Supreme Court
District USSup
Opinion Date: 03/19/2008
Subsequent History: 128 S.Ct. 1203, 170 L.Ed.2d 175
Summary

The trial court erred when it rejected petitioner’s Batson claim. During voir dire in Snyder’s capital murder trial, the prosecutor used peremptory challenges to eliminate black prospective jurors who had survived challenges for cause. The Louisiana Supreme Court rejected Snyder’s Batson claim. The United States Supreme Court reversed, finding that the trial court committed clear error in rejecting the Batson objection. The prosecutor justified his challenge of juror Brooks by stating that Brooks was a college senior attempting to fulfill his student teaching obligation, and that he looked “nervous.” The explanation was insufficient for a Batson determination. Brooks was one of more than 50 venire members who expressed concerns that jury service would interfere with other obligations. The prosecutor did not question Brooks more deeply on the matter. The prosecutor’s explanation that Brooks would decide the case in a way to avoid a penalty phase, was highly speculative and unlikely. The implausibility of the prosecutor’s explanation was reinforced by his acceptance of white jurors with similar conflicting obligations. The pretextual obligation gives rise to an inference of discriminatory intent. J. Thomas and Scalia dissented.