Batson v. Kentucky

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Following is the case brief for Batson v. Kentucky, Supreme Court of the United States, (1986)

Case summary for Batson v. Kentucky:

  • Batson, an African American was charged with burglary and receiving stolen property.
  • The state used all their peremptory challenges to keep African Americans off the jury.
  • Batson was convicted and claimed that the use of peremptory challenges based on race were unconstitutional.
  • The Court held that to establish a prima facie case of discrimination, the defendant must show they are part of a specific racial group, the prosecution used its peremptory challenges to remove possible jury members part of the same racial group and that in light of all surrounding circumstances, the prosecutor used the practice to exclude possible jury members based on race.

Case Brief for Batson v. Kentucky

Statement of the facts:

Batson, an African American man, was charged with burglary and receiving stolen goods. When selecting the jury, the prosecution used up all of his peremptory challenges to discharge all of the African Americans. In response, Batson petitioned to discharge the existing jury alleging the exclusion violated his 14th Amendment Equal Protection rights. His petition was denied and he was found guilty of burglary and receiving stolen property.

Procedural History:

The trial court judge denied Batson’s request and he appealed. The state supreme court affirmed the lower court’s decision and Batson petitioned for certiorari.

Rule of Law or Legal Principle Applied:

When the defendant proves prima facie discrimination, the prosecution must provide a neutral explanation for challenging a possible juror since Equal Protection prevents the state from prohibiting African Americans from the venire. Equal Protection also stops the prosecution from striking an African American simply because the defendant is African American.

Issue and Holding:

If the prosecution thinks African American jurors cannot be impartial due to the fact the defendant is also African American, will the defendant’s rights be violated if all the state’s preemptory challenges are used to exclude African Americans from the jury? Yes.

Judgment:

The Court reversed the lower court’s decision.

Reasoning:

The Court held when the prosecution excludes African American veniremen from the jury based on a mere presumption of bias in favor of an African American defendant, the Equal Protection Clause is violated. As a result, if the defendant makes a prima facie showing of discrimination during the peremptory challenge, the state can be compelled to provide the court with a neutral explanation for its challenge of a certain veniremen. The Court also held that since there is no constitutional right to peremptory challenges there exists no issue in limiting its reach.

The Court pointed out its holding in Swain v. Alabama, 380 U.S. 202 (1965) which set the precedent for peremptory challenges being subject to equal protection principles. Following cases have set the standard for proving purposeful discrimination prima facie.  The defendant must show they are part of a specific racial group, the prosecution has used its peremptory challenges to remove possible jury members who are part of the same racial group and the defendant must show that in light of all the surrounding circumstances, the prosecutor used the practice to exclude possible jury members based on their race. Evidence of prior patterns of discrimination by a specific prosecutor is not necessary.

The Court held that when the defendant has proven the above requirements, the burden then shifts to the state to provide a neutral explanation to justify the challenge.

Concurring or Dissenting opinion:

Concurring (Marshall):

Overall, the Majority is correct. The end racial discrimination in jury selection, peremptory challenges, for both sides needs to be eliminated. This is because it is difficult to judge the true motives behind such challenges, as a false reason could be provided.

Dissenting (Rehnquist):

Here the Court misapplied the Equal Protection Clause.  The state’s exclusion of African American jurors when the defendant is African American is not unequal. This is because the technique could be applied across the board despite the defendant’s race, class or other group they may fall into.

Significance:

This case set out the standard for questioning the constitutionality of peremptory challenges.

Student Resources:

https://supreme.justia.com/cases/federal/us/476/79/
https://www.law.cornell.edu/supremecourt/text/476/79