Ann Catherine Reese v. State, 12-16-00143-CR

Appellant Ann Catherine Reese pleaded guilty to DWI; jury trial proceeded on punishment where she received 90 days confinement.
During voir dire the State used a peremptory strike against Venire Member No. 10, an African American juror.
Reese objected under Batson, arguing the strike was race-based; the trial court held a Batson inquiry.
The State offered two race-neutral reasons: (1) the venire member indicated a tendency to be lenient on first-time offenders; (2) the venire member allegedly nodded in agreement when another panelist criticized the district attorney’s plea practices.
Appellant’s counsel conceded he had not observed the nodding; he offered no further rebuttal to the State’s explanations.
The trial court overruled the Batson challenge; the court of appeals affirmed, finding the State’s reasons race-neutral and not shown to be pretextual.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State’s peremptory strike of an African American juror violated Batson	Reese: strike was race-based because juror is African American and within minority strike zone	State: struck juror for race-neutral reasons — perceived leniency toward first-time offenders and observed nodding in agreement with criticism of DA	Court: State’s reasons are facially race-neutral and not proven pretextual; Batson challenge overruled

Batson v. Kentucky, 476 U.S. 79 (prohibits racial discrimination in peremptory strikes)
Snyder v. Louisiana, 552 U.S. 472 (describes Batson three-step framework)
Purkett v. Elem, 514 U.S. 765 (facial validity of prosecutor’s race-neutral explanation)
Watkins v. State, 245 S.W.3d 444 (burden-shifting and pretext analysis under Batson in Texas)
Williams v. State, 301 S.W.3d 675 (discusses Batson and race-neutral explanations)
Moore v. State, 265 S.W.3d 73 (defendant may continue rebuttal during Batson process)
Young v. State, 283 S.W.3d 854 (trial court factfinding role in Batson determinations)