Saturday, November 2, 2013

Batson v. Kentucky case brief

Batson v. Kentucky case brief summary
476 U.S. 79 (1986)

CASE SYNOPSIS
Petitioner appealed the decision of the Supreme Court of Kentucky that affirmed his conviction despite petitioner's claim that he was denied equal protection through the prosecutor's use of peremptory challenges to exclude members of his race from the petit jury at his trial.

CASE FACTS

  • At trial, the prosecutor used his peremptory challenges to strike all four minority persons on the venire, and a jury composed only of Caucasians was selected.
  •  On petitioner's objection, the trial judge observed that the parties were entitled to use peremptory challenges to strike anyone for any reason. 
  • On appeal to the state supreme court, petitioner contended the facts established that the prosecution had engaged in a systematic pattern of discriminatory challenges, thus establishing an equal protection violation. 
  • The state supreme court affirmed the conviction. 
DISCUSSION

  • The Court reversed and remanded the case to the trial court, holding that if the trial court decided that the facts established prima facie, purposeful discrimination and that the prosecution did not proffer a neutral explanation for its actions, petitioner's conviction had be reversed. 
  • The Court overruled Swain v. Alabama, 380 U.S. 202 (1965), to the extent that it required petitioner to establish a systematic pattern of discrimination in jury selection.

CONCLUSION

The Court reversed petitioner's conviction and remanded the case to the trial court for a determination of whether the facts established a prima facie case for purposeful discrimination in the prosecution's use of peremptory challenges in jury selection; the requirement of proving a systematic pattern of discrimination was overruled.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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