State v. Curry

"The discriminatory use of peremptory challenges by the prosecution causes a criminal defendant cognizable injury. . . [r]ather it is because racial discrimination in the selection of jurors 'casts doubt on the integrity of the judicial process,' and paces the fairness of a criminal proceeding in doubt." Powers v. Ohio, 499 US 400, 411-12, 111 S Ct 1364, 113 L Ed 2d 411 (1991).

Defendant appealed the trial court's decision during the voir dire stage of Defendant's jury trial.  Defendant assigned error to the court's decision to overrule the Batson challenge and allow the prosecutor's peremptory challenge.   On appeal, Defendant argued that the prosecution's justification on a peremptory strike was an excuse for a racially motivated jury selection.  In response, the State argued that the prosecutor's decision to strike the juror was made before learning about his race, thus, the decision was not racially motivated.  "The discriminatory use of peremptory challenges by the prosecution causes a criminal defendant cognizable injury. . . [r]ather it is because racial discrimination in the selection of jurors 'casts doubt on the integrity of the judicial process,' and paces the fairness of a criminal proceeding in doubt." Powers v. Ohio, 499 US 400, 411-12, 111 S Ct 1364 (1991).  Considering the trial court's ruling through a comparative juror analytical lens, the Court held that the trial court ruling was clearly erroneous because the record only supports pretextual reasons for striking the juror, since similarly unemployed, young, white college students were uncontested.  Reversed and remanded.