Addison v. State, 2012 Ind. LEXIS 20

Addison, an African American, was charged with murder and handgun offenses after a December 2008 shooting.
Jury venire was questioned in two panels; three African American venirepersons were struck on the first panel.
Addison lodged a Batson objection alleging purposeful race-based striking; state acknowledged prima facie discrimination and gave race-neutral reasons for Turner’s strike.
Turner’s stated response to insanity-question discussions suggested reliance on professionals; the state argued this showed bias against Turner.
Trial court denied the Batson objection; later proceedings resulted in a guilty but mentally ill verdict and a 45-year sentence.
Indiana Court of Appeals affirmed on non-Batson issues and remanded for new trial on Batson grounds; Indiana Supreme Court granted transfer.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Turner’s strike was race-based discrimination	Addison argues the state’s reasons were pretextual.	State contends Turner’s remarks showed non-racial concerns about insanity testimony.	Batson violation found; Turner struck for race.
Proper appellate standard for waived Batson claims in Indiana	Waiver should be overcome under fundamental error review.	Waiver should bar appellate consideration unless fundamental error exists.	Fundamental error doctrine permits review of waived Batson claim.
Whether the trial court properly conducted the Batson three-step framework	Turner’s race-neutral reasons should be scrutinized for pretext.	State’s reasons were race-neutral and credible.	Trial court failed to perform explicit third-step credibility assessment; remand for retrial.
Effect of non-minority jurors with similar responses to Turner	Some non-black jurors gave similar responses to insanity questions yet were seated.	Those jurors did not face the same peremptory challenge; Turner was singled out.	Comparative analysis supports pretext finding; strengthens Batson violation.
Remedy for Batson violation	New trial is warranted due to peremptory-challenge-based discrimination.	No alternative remedy proposed beyond remedy in Batson framework.	Reverse and remand for a new trial.

Batson v. Kentucky, 476 U.S. 79 (Supreme Court 1986) (prohibits racial discrimination in jury selection)
Snyder v. Louisiana, 552 U.S. 472 (Supreme Court 2008) (infers equal protection violation from arbitrary exclusion)
Miller-El v. Dretke, 545 U.S. 231 (Supreme Court 2005) (pretext analysis; side-by-side juror comparison permissible)
Purkett v. Elem, 514 U.S. 765 (Supreme Court 1995) (race-neutral explanations need not be persuasive)
Hernandez v. New York, 500 U.S. 352 (Supreme Court 1991) (race-neutral explanations remain subject to ultimate inquiry)
Jeter v. State, 888 N.E.2d 1257 (Indiana 2008) (Indiana Batson framework discussed)
Smylie v. State, 823 N.E.2d 679 (Indiana 2005) (fundamental error analogue in Indiana Batson review)
Highler v. State, 854 N.E.2d 823 (Indiana 2006) (race-based challenges and voir dire considerations)
United States v. Rutledge, 648 F.3d 555 (7th Cir. 2011) (separation of Batson steps; explicit step-three analysis)