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SNYDER v. LOUISIANA (No. 06-10119)
Web-accessible at:
http://www.law.cornell.edu/supct/html/6-10119.ZS.html
Argued: December 4, 2007 -- Decided: March 19, 2008
Opinion author: Alito
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During voir dire in petitioner's capital murder case, the
prosecutor used peremptory strikes to eliminate black prospective
jurors who had survived challenges for cause. The jury
convicted petitioner and sentenced him to death. Both on
direct appeal and on remand in light of Miller-El v. Dretke,
545 U. S. 231 , the Louisiana Supreme Court rejected petitioner's
claim that the prosecution's peremptory strikes of certain
prospective jurors, including Mr. Brooks, were based on
race, in violation of Batson v. Kentucky, 476 U. S. 79
..
Held: The trial judge committed clear error in rejecting
the Batson objection to the strike of Mr. Brooks. Pp. 3-13.
(a) Under Batson's three-step process for adjudicating
claims such as petitioner's, (1) a defendant must make
a prima facie showing that the challenge was based on race;
(2) if so, " 'the prosecution must offer a race-neutral
basis for striking the juror in question' "; and (3) "
'in light of the parties' submissions, the trial court
must determine whether the defendant has shown purposeful
discrimination.' " Miller-El, supra, at 277 (Thomas, J.,
dissenting) (quoting Miller-El v. Cockrell, 537 U. S. 322
). Unless it is clearly erroneous, the trial court's ruling
must be sustained on appeal. The trial court's role is
pivotal, for it must evaluate the demeanor of the prosecutor
exercising the challenge and the juror being excluded.
Pp. 3-4.
(b) While all of the circumstances bearing on the racial-animosity
issue must be consulted in considering a Batson objection
or reviewing a ruling claimed to be a Batson error, the
explanation given for striking Mr. Brooks, a college senior
attempting to fulfill his student-teaching obligation,
is insufficient by itself and suffices for a Batson error
determination. Pp. 4-13.
(1) It cannot be presumed that the trial court credited
the prosecution's first race-neutral reason, that Mr. Brooks
looked nervous. Deference is owed to a trial judge's finding
that an attorney credibly relied on demeanor in exercising
a strike, but here, the trial judge simply allowed the
challenge without explanation. Since Mr. Brooks was not
challenged until the day after he was questioned and thus
after dozens of other jurors had been called, the judge
might not have recalled his demeanor. Or he may have found
such consideration unnecessary, instead basing his ruling
on the second proffered reason for the strike. P. 6.
(2) That reason--Mr. Brooks' student-teaching obligation--fails
even under the highly deferential standard of review applicable
here. Mr. Brooks was 1 of more than 50 venire members expressing
concern that jury service or sequestration would interfere
with work, school, family, or other obligations. Although
he was initially concerned about making up lost teaching
time, he expressed no further concern once a law clerk
reported that the school's dean would work with Mr. Brooks
if he missed time for a trial that week, and the prosecutor
did not question him more deeply about the matter. The
proffered reason must be evaluated in light of the circumstances
that the colloquy and law clerk report took place on Tuesday,
the prosecution struck Mr. Brooks on Wednesday, the trial's
guilt phase ended on Thursday, and its penalty phase ended
on Friday. The prosecutor's scenario--that Mr. Brooks would
have been inclined to find petitioner guilty of a lesser
included offense to obviate the need for a penalty phase--is
both highly speculative and unlikely. Mr. Brooks would
be in a position to shorten the trial only if most or all
of the jurors had favored a lesser verdict. Perhaps most
telling, the trial's brevity, which the prosecutor anticipated
on the record during voir dire, meant that jury service
would not have seriously interfered with Mr. Brooks' ability
to complete his student teaching. The dean offered to work
with him, and the trial occurred relatively early in the
fall term, giving Mr. Brooks several weeks to make up the
time. The implausibility of the prosecutor's explanation
is reinforced by his acceptance of white jurors who disclosed
conflicting obligations that appear to have been at least
as serious as Mr. Brooks'. Under Batson's third stage,
the prosecution's pretextual explanation gives rise to
an inference of discriminatory intent. There is no need
to decide here whether, in Batson cases, once a discriminatory
intent is shown to be a motivating factor, the burden shifts
to the prosecution to show that the discriminatory factor
was not determinative. It is enough to recognize that a
peremptory strike shown to have been motivated in substantial
part by discriminatory intent could not be sustained based
on any lesser showing by the prosecution. The record here
does not show that the prosecution would have pre-emptively
challenged Mr. Brooks based on his nervousness alone, and
there is no realistic possibility that the subtle question
of causation could be profitably explored further on remand
more than a decade after petitioner's trial. Pp. 6-13.
942 So. 2d 484, reversed and remanded.
Alito, J., delivered the opinion of the Court, in which
Roberts, C. J., and Stevens, Kennedy, Souter, Ginsburg,
and Breyer, JJ., joined. Thomas, J., filed a dissenting
opinion, in which Scalia, J., joined.
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