Batson V. Kentucky Jury Selection Discrimination Case
1. Batson v. Kentucky (1986)
Facts:
Batson, an African American, was on trial for burglary and receipt of stolen goods.
During jury selection, the prosecutor used peremptory challenges to exclude all Black potential jurors.
Batson argued this violated his rights under the Equal Protection Clause of the 14th Amendment.
Legal Issue:
Can prosecutors use peremptory challenges to exclude jurors solely based on race?
Supreme Court Holding:
The Court ruled no.
Prosecutors cannot use peremptory challenges to exclude jurors based on race.
Established a three-step process for challenging peremptory strikes:
Defendant must show a prima facie case of racial discrimination.
Prosecutor must provide a race-neutral explanation.
Court decides if the explanation is genuine or pretextual.
Significance:
A major step toward ensuring fairness and diversity in juries.
Focused on eliminating racial discrimination in jury selection.
2. Georgia v. McCollum (1992)
Facts:
McCollum, a white defendant, was accused of assault.
During jury selection, McCollum’s defense team used peremptory challenges to exclude Black jurors.
Legal Issue:
Does Batson’s prohibition of race-based peremptory challenges apply to the defense, not just prosecutors?
Supreme Court Holding:
Yes.
Both prosecution and defense are barred from racial discrimination in jury selection.
Significance:
Expanded Batson to all parties in jury selection.
Reinforced equal protection principles.
3. J.E.B. v. Alabama (1994)
Facts:
The defendant was a man accused of child support violations.
The state used peremptory challenges to exclude jurors based on gender.
Legal Issue:
Does Batson extend to gender-based peremptory challenges?
Supreme Court Holding:
Yes.
Gender-based exclusions violate the Equal Protection Clause, just like race-based ones.
Significance:
Extended Batson’s anti-discrimination principle beyond race to gender.
Set precedent for challenging sex-based jury exclusions.
4. Purkett v. Elem (1995)
Facts:
Elem was convicted of murder.
Prosecutors used peremptory challenges to exclude African-American jurors.
They gave a race-neutral explanation (jurors appeared uninterested or nervous).
Legal Issue:
What qualifies as a “race-neutral” explanation under Batson?
Supreme Court Holding:
The Court held that a race-neutral explanation doesn’t need to be plausible, just genuine.
The trial court’s decision on the credibility of the explanation is key.
Significance:
Made it easier for prosecutors to meet their burden.
Highlighted the trial court’s role in evaluating Batson claims.
5. Flowers v. Mississippi (2019)
Facts:
Flowers, an African American man, was tried six times for the same murders.
Prosecutors struck Black jurors disproportionately each time.
Legal Issue:
Did the prosecutors repeatedly violate Batson by racially excluding jurors?
Supreme Court Holding:
Yes.
The Court found a pattern of racial discrimination violating Batson.
Reversed Flowers’ conviction.
Significance:
Emphasized Batson’s importance in preventing systemic racial discrimination.
Shows courts will scrutinize patterns of strikes over multiple trials.
Summary Table:
| Case | Issue | Holding | Significance |
|---|---|---|---|
| Batson v. Kentucky | Racial discrimination in jury | Prohibited race-based strikes | Foundation of Batson rule |
| Georgia v. McCollum | Defense racial strikes | Barred defense from racial strikes | Equal protection applies to defense |
| J.E.B. v. Alabama | Gender discrimination in jury | Barred gender-based strikes | Extended Batson to sex discrimination |
| Purkett v. Elem | What counts as race-neutral reason? | Any genuine reason suffices | Trial judge decides credibility |
| Flowers v. Mississippi | Repeated racial strikes | Found violation and reversed | Focus on patterns, not single strikes |
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