Eugene Roach v. State of Indiana
2017 Ind. App. LEXIS 264
| Ind. Ct. App. | 2017Background
- Trooper observed Roach strike a woman near a bicycle, called "Hey, stop, police!" and Roach rode away; a bystander blocked him and Trooper Bennett arrested him.
- State charged Roach with Level 6 felony criminal confinement, Class A misdemeanor battery, and Class A misdemeanor resisting law enforcement; confinement and battery later dismissed; trial on resisting charge resulted in conviction.
- During voir dire, Juror Kevin ("Juror Wilson") — the only African American male in the panel — gave brief, partially inaudible answers; the State used a peremptory strike against him.
- Defense raised a Batson challenge arguing the strike was race-based; the State offered two race-neutral reasons: (1) juror demeanor/body language and (2) that juror said he would not stop for police (a factual claim unsupported by the record audio).
- Trial court denied the Batson challenge with a short statement that it did not find purposeful discrimination; Roach appealed, arguing the denial was erroneous because the record undermined the State's reasons and the court made no credibility findings about demeanor.
- The Court of Appeals remanded for the trial court to make findings on whether the State’s demeanor-based justification was credible because one proffered reason was a mischaracterization of voir dire, leaving only the subjective demeanor reason for review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court properly denied Roach's Batson challenge to the peremptory strike of Juror Wilson | State: strike was race-neutral based on juror’s body language and an asserted statement that juror would not stop for police | Roach: strike was pretextual and racially motivated; State mischaracterized juror’s answers and offered only subjective demeanor reasoning without trial-court credibility findings | Court: remanded — trial court must make findings on the credibility of the demeanor-based justification; one of the State's reasons was unsupported by the record, so the court's terse denial was insufficient for appellate review |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (race-based peremptory strikes violate Equal Protection)
- Snyder v. Louisiana, 552 U.S. 472 (trial court must assess and on-recordly credit demeanor justifications; lack of findings undermines review)
- Miller-El v. Dretke, 545 U.S. 231 (court must assess plausibility of prosecutor’s explanation; comparative juror analysis relevant)
- Addison v. State, 962 N.E.2d 1202 (Ind. 2012) (trial court must evaluate persuasiveness of prosecutor’s race-neutral explanation; mischaracterizations can show pretext)
- Jeter v. State, 888 N.E.2d 1257 (Ind. 2008) (Batson framework and application in Indiana)