Cartwright v. State
2012 Ind. LEXIS 19
| Ind. | 2012Background
- Cartwright was convicted of attempted battery and unlawful possession of a firearm by a serious violent felon; trial on those counts was bifurcated from other charges.
- During jury selection the State peremptorily struck the sole African American venireperson, Bard, triggering a Batson challenge by Cartwright.
- The trial court did not find a prima facie case of discrimination but allowed a Batson hearing and heard the State’s race-neutral explanations.
- A Batson hearing was held; the State offered race-neutral reasons, and the court denied the challenge, finding no discriminatory purpose.
- The Court of Appeals reversed in a divided decision on Batson and the sufficiency of the attempted battery convictions; we granted transfer and affirm the trial court’s Batson ruling and summarily affirm the sufficiency ruling.
- The Court holds that the State’s reasons for striking Bard were race-neutral and that Cartwright failed to prove pretext or purposeful discrimination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Batson challenge to Bard strike | Cartwright argues Bard was singled out due to race | State asserts race-neutral, non-demeanor reasons | Batson claim affirmed; strike not shown discriminatory |
| Sufficiency of evidence for attempted battery | Evidence insufficient for attempted battery with deadly weapon | Evidence sufficient for convictions | Sufficiency claim summarily affirmed (no reversal) |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (1986) (racial discrimination in jury selection violates Fourteenth Amendment)
- Snyder v. Louisiana, 552 U.S. 472 (2008) (requires careful evaluation of race-neutral explanations; demeanor issues require record to show relied upon)
- Miller-El v. Dretke, 545 U.S. 231 (2005) (reiterates three-step Batson framework and discriminatory intent analysis)
- Jeter v. State, 888 N.E.2d 1257 (Ind.2008) (Indiana application of Batson framework)
- Addison v. State, 962 N.E.2d 1202 (Ind.2012) (recognizes requirement of prima facie showing and deference on ultimate discrimination question)