Batson v. Kentucky
Citation: 476 U.S. 79 (1986)
Facts
James Batson, a Black man, was tried for burglary and receipt of stolen goods in Kentucky. The prosecutor used peremptory challenges to strike all four Black jurors from the venire, resulting in an all-white jury. Batson was convicted. He argued that the systematic exclusion of Black jurors violated his equal protection rights.
Issue
Whether the Equal Protection Clause prohibits a prosecutor from using peremptory challenges to exclude jurors solely on the basis of race.
Holding
The Supreme Court overruled Swain v. Alabama and held that the Equal Protection Clause prohibits racially discriminatory use of peremptory challenges. The Court established a three-step burden-shifting framework for defendants to raise equal protection challenges.
Rule
A defendant may establish a prima facie case of racial discrimination in jury selection by showing the prosecutor used peremptory challenges to remove members of the defendant’s race. The burden then shifts to the prosecution to offer a race-neutral explanation, and the trial court must determine whether the explanation is genuine.
Significance
Batson is the landmark case on racial discrimination in jury selection. It spawned a vast body of litigation about what constitutes a race-neutral explanation and how courts evaluate pretext. Its reach has been extended to gender (J.E.B. v. Alabama) and to civil cases, and it remains at the center of debates about systemic racism in jury selection.