Williams’s first trial for theft and misappropriation of public funds ended in a mistrial when an African-American juror refused to deliberate. During voir dire for his second trial, the prosecutor used a peremptory challenge to excuse an an African-American juror. The stated reasons were that he was concerned about jury ification, and that the juror was in a similar situation to a hostile witness and he feared that she would not judge the witness’s testimony fairly. He also noted that she was evasive and distant with the prosecutor, but friendly and open with defense counsel. The trial court overruled Williams’s Batson/Wheeler objection. The appellate court here affirmed. The prosecutor proffered race neutral reasons for excusing the juror and Williams failed to meet his burden of proving that the prosecutor was motivated by race in using his peremptory challenge.