Adair v. State, 336 S.W.3d 680

Appellant James Lance Adair was convicted by a jury of possession of methylenedioxy methamphetamine (ecstasy) weighing 4–400 grams.
Appellant pleaded true to two enhancement paragraphs after the jury verdict, leading to a 25-year confinement sentence.
The enhancements alleged two prior felonies: a 1997 possession with intent to deliver, and a 2002 evading arrest with a motor vehicle, finalized before the present offense.
The trial court approved a stipulation of evidence admitting the enhancement convictions and advised Adair that his plea to the enhancements would be true.
The State challenged Batson purposes in striking African-American venire members; the trial court denied the Batson challenge after a hearing.
The court upheld the State’s jury-argument rulings, determining the references to Adair as a 'dope dealer' were legitimate pleas for law enforcement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Batson challenge denial	Adair	Adair contends the State struck Black jurors unlawfully	Denied; trial court did not err
Finality of enhancement convictions	Adair	Adair argues enhancements were not final for §12.42 purposes	Evidence sufficient; enhancements final
Improper jury argument	Adair	Adair argues references to him as a 'dope dealer' were improper	Arguments were proper pleas for law enforcement

Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (prohibits race-based peremptory strikes)
Snyder v. Louisiana, 552 U.S. 472 (U.S. 2008) (three-step Batson framework)
Watkins v. State, 245 S.W.3d 444 (Tex. Crim. App. 2008) (non-exclusivity of Batson factors)
Purkett v. Elem., 514 U.S. 765 (U.S. 1995) (race-neutral explanations presumed valid unless pretext)
Miller-El v. Cockrell, 537 U.S. 322 (U.S. 2003) (pretext and plausibility of explanations govern discrimination finding)
Young v. State, 283 S.W.3d 854 (Tex. Crim. App. 2009) (limits on comparative juror analysis on appeal)
Cornish v. State, 848 S.W.2d 144 (Tex. Crim. App. 1993) (juror information cards can be considered on appeal when raised)
Vargas v. State, 838 S.W.2d 556 (Tex. Crim. App. 1992) (juror card evidence treated carefully in Batson review)
Davis v. State, 830 S.W.2d 762 (Tex. App. Houston [1st Dist.] 1992) (permissible inferences in closing argument from trial evidence)
Akin v. State, 981 S.W.2d 297 (Tex. App.-Texarkana 1998) (drug-dealer inference permissible in possession cases)
Greer v. State, 310 S.W.3d 11 (Tex. App.-Dallas 2009) (pretext must be clearly contrary to evidence to reverse Batson ruling)
Bentley-Smith v. United States, 2 F.3d 1368 (5th Cir. 1993) (pretext evidence in Batson analysis)