RESPONDENT: State of Louisiana
LOCATION: Earthquake Park
DOCKET NO.: 06-10119
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: Louisiana Supreme Court
CITATION: 552 US 472 (2008)
GRANTED: Jun 25, 2007
ARGUED: Dec 04, 2007
DECIDED: Mar 19, 2008
Stephen B. Bright - on behalf of the Petitioner
Terry M. Boudreaux - on behalf of the Respondent
Facts of the case
In capital murder trial of Allen Snyder, an African-American, the prosecution used peremptory (automatic) challenges to dismiss five African-American prospective jurors. This resulted in Snyder being tried by an all-white jury, which found him guilty and approved the death penalty. The defense argued that the prosecution's striking of the black jurors was racial discrimination in violation of the Equal Protection Clause, according to the standard set forth by the Supreme Court in Batson v. Kentucky. As part of its case for the prosecution's alleged discriminatory intent, the defense cited two of the prosecutor's statements comparing the case to the O.J. Simpson murder trial. After having indirectly referred to the Simpson trial before jury selection, the prosecutor had invoked the case again during the sentencing phase, comparing aspects of Snyder's case to Simpson's and noting that the latter defendant "got away with it." The trial court applied the Batson framework and denied the defense's challenges.
On appeal, the Louisiana Supreme Court upheld the trial court, ruling that the trial judge had not acted unreasonably when he accepted the prosecution's race-neutral justifications for the dismissals of the black jurors. The court ruled that the O.J. Simpson references were harmless comparisons made in the course of a rebuttal, and it noted that the prosecution had not mentioned Simpson's or Snyder's race. When the Supreme Court instructed the state court to reconsider the case in light of Miller-El v. Dretke, which requires that courts consider the totality of the circumstances when evaluating discriminatory intent, the court affirmed the trial court a second time.
Did the state's dismissal by peremptory challenge of all of the black potential jurors, combined with the prosecution's comparisons of the case to the O.J. Simpson trial, amount to a violation of the Equal Protection Clause?
Media for Snyder v. LouisianaAudio Transcription for Oral Argument - December 04, 2007 in Snyder v. Louisiana
Audio Transcription for Opinion Announcement - March 19, 2008 in Snyder v. Louisiana
Samuel A. Alito, Jr.:
And this case comes to us on writ of certiorari to the Louisiana Supreme Court.
Petitioner Allen Snyder was convicted of first-degree murder in a Louisiana court and sentenced to death.
The Louisiana Supreme Court rejected petitioner's claim that the prosecution exercised some of its peremptory strikes based on race in violation of Batson versus Kentucky because we find that the trial court committed clear error in overruling a Batson objection to the strike of juror Jeffrey Brooks, we reverse.
Batson provides a three-step process for trial court to use in deciding a claim regarding a peremptory challenge that is alleged to have been based on race.
This case concerns the third step of that process at which the trial court must determine whether the objecting party had shown intentional discrimination because the third step often involves credibility, determinations and firsthand observations that are peculiarly within the trial court's province, the trial court's ruling should be disturbed only when there is clear error.
The prosecution gave two reasons for striking Mr. Brooks, a college senior.
First, that Mr. Brooks looked nervous during voir dire.
And second, that Mr. Brooks expressed the concern that service on the jury would conflict with his student teaching obligations.
The trial court did not explain the basis for overruling the Batson objection and we therefore cannot presume that the trial judge made a finding on Mr. Brooks' demeanor.
Indeed, the prosecution struck Mr. Brooks a day after he was questioned during voir dire.
The judge may not have even remembered Mr. Brooks' demeanor at that point or may have found it unnecessary to consider his demeanor basing his ruling on the second proffered justification alone.
The second justification fails even the deferential standard of review applicable here.
When Mr. Brooks came forward to express concern that jury service would conflict with his student teaching obligations, the Court called the dean at Mr. Brooks' college.
The dean said that there would not be a problem if Mr. Brooks missed one week of student teaching.
During voir dire, the prosecutor stated that he did not think that the trial would last through the weekend, and it did not.
If Mr. Brooks had served on the jury, he would have missed only two additional days of student teaching.
The implausibility of this explanation is reinforced by the prosecutor's acceptance of white jurors who disclosed conflicting obligations that appeared to have been at least as serious as Mr. Brooks'.
The pretextual explanation of the strike of Mr. Brooks naturally gives rise to an inference of discriminatory intent.
In other context, we have held that once it is shown that a discriminatory intent was a substantial or motivating factor in an action taken by a state actor, the burden shifts to the State to show that the factor was not determinative.
Assuming that the standard applies in the Batson context, we conclude that the record does not show that the prosecution would have challenged Mr. Brooks based on his alleged nervousness alone.
We therefore reverse the judgment of the Louisiana Supreme Court.
Justice Thomas has filed a dissenting opinion in which Justice Scalia has joined.