City of Seattle v. Erickson, 93408-8

Background

In 2013 Matthew Erickson (Black) was charged in Seattle Municipal Court with unlawful use of a weapon and resisting arrest; after voir dire the City used a peremptory strike on juror 5, the only Black juror on the panel.
The six-person jury was empaneled, the venire excused, and the jury dismissed for the day; Erickson then objected under Batson, claiming the strike was race-motivated.
The municipal court found Erickson’s Batson objection timely but concluded he had not established a prima facie case because other jurors from "people of color" remained on the panel; Erickson was convicted.
Superior court and Court of Appeals denied relief; the Washington Supreme Court granted review.
The Supreme Court held Erickson’s Batson challenge was timely and adopted a bright-line rule: striking the sole member of a cognizable racial group from a jury panel establishes a prima facie case requiring a full Batson inquiry.
Because the trial judge who heard the original challenge was unavailable and demeanor findings could not be reliably reconstructed, the court reversed and remanded for a new trial.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of Batson objection raised after empaneling and dismissal of venire	Erickson: objection was first practicable moment to object outside jurors' presence; trial court still could remedy	City: objection was untimely because raised after jury empaneled and venire dismissed	Timely: objection was filed at the earliest reasonable time while court could still remedy error
Prima facie showing when prosecutor strikes the only juror of a cognizable racial group	Erickson: striking the sole Black juror creates a prima facie inference of racial discrimination (bright-line rule)	City: single strike does not show pattern; presence of other nonwhite jurors shows lack of discriminatory intent	Held: striking the only member of a cognizable racial group establishes a prima facie case; court must require race-neutral explanation and proceed with full Batson analysis
Scope of Batson standard in Washington (whether to adopt Rhone dissent bright-line rule)	Erickson: Washington should adopt bright-line rule to better protect equal protection in jury selection	City: stick with existing discretionary, fact-specific Batson analysis requiring more than a single strike	Held: Washington adopts the bright-line rule from the Rhone dissent—sole-member strike triggers prima facie showing
Appropriate remedy for Batson error discovered post-conviction	Erickson: with judge unavailable and time elapsed, remand for new trial	City: remand for Batson hearing or other lesser relief	Held: reversal and remand for new trial (mistrial/remedy impracticable due to judge unavailability and time lapse)

Key Cases Cited

Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (established three‑step test prohibiting race‑based peremptory strikes)
Johnson v. California, 545 U.S. 162 (U.S. 2005) (court must weigh credibility and circumstances when deciding purposeful discrimination)
Snyder v. Louisiana, 552 U.S. 472 (U.S. 2008) (Constitution forbids striking even a single juror for discriminatory purpose)
Hernandez v. New York, 500 U.S. 352 (U.S. 1991) (deference to trial court credibility determinations in Batson analysis)
State v. Hicks, 163 Wn.2d 477 (Wash. 2008) (trial court within discretion to find prima facie case when sole Black juror struck)
State v. Rhone, 168 Wn.2d 645 (Wash. 2010) (declined to adopt bright‑line rule; dissent proposed such rule)
State v. Meredith, 178 Wn.2d 180 (Wash. 2013) (clarified Rhone; noted bright‑line rule could be applied prospectively if adopted by majority)
State v. Saintcalle, 178 Wn.2d 34 (Wash. 2013) (discussed Batson’s limitations and court's discretion to alter framework)