Eddie Howard Richardson v. State of Florida, 392 So.3d 1109

Eddie Howard Richardson was convicted by a jury of attempted manslaughter, aggravated assault, possession of a firearm by a convicted felon, and failure to appear in court while on bail.
During jury selection, Richardson objected to the State's use of peremptory challenges to strike two African American women from the jury panel.
Richardson requested the State provide race-neutral reasons for these strikes; the State articulated reasons seen as facially race-neutral.
The trial court accepted the State's reasons as race-neutral, and Richardson did not further argue or request a finding that the State's reasons were pretextual (i.e., not genuine).
On appeal, Richardson contended the trial court mishandled the peremptory challenge process, claiming improper exclusion of jurors on racial grounds.
The appellate court found Richardson did not properly preserve his objections for appellate review and thus affirmed the trial court's decision.

Issue	Richardson's Argument	State's Argument	Held
Whether peremptory strikes were racially discriminatory and improperly allowed	State's reasons were not truly race-neutral (improper purpose)	Reasons were facially race-neutral (appearance, residence)	Richardson failed to preserve the issue; affirmed trial court
Whether preservation requirements under Melbourne and Johnson were met	Argued objections sufficiently preserved	Argued preservation required further challenge to genuineness	Not preserved; burden was on objector to challenge genuineness

Melbourne v. State, 679 So. 2d 759 (Fla. 1996) (sets out three-step process for evaluating race-based objections to peremptory challenges)
State v. Johnson, 295 So. 3d 710 (Fla. 2020) (clarifies preservation requirements for challenges to peremptory strikes on racial grounds)