Floyd v. State
190 So. 3d 972
Ala.2012Background
- Floyd was convicted of capital murder during a robbery and sentenced to death by a jury (11-1 in favor of death).
- On direct appeal, Floyd challenged the State’s use of peremptory challenges to strike African-American and female jurors, alleging Batson/J.E.B. violations; the Court of Criminal Appeals found an inference of discrimination and remanded for Batson/J.E.B. proceedings.
- On remand, the trial court conducted Batson/J.E.B. proceedings and concluded the State articulated race- and gender-neutral reasons for most strikes but did not issue specific findings for two strikes (jurors 5 and 58).
- The Court of Criminal Appeals affirmed Floyd’s conviction and sentence, noting the State’s reasons for jurors 5 and 58 were race- and gender-neutral, and that the trial court’s remand instructions were satisfied in part.
- This Court granted certiorari to review whether the Court of Criminal Appeals, after its plain-error review, recognized prejudicial plain errors and whether the Batson issue was properly handled; the Court reverses and remands for further findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State’s strikes of African-American and female jurors violated Batson | Floyd argues the record shows purposeful discrimination based on race/gender. | Floyd's argument relies on plain-error review to evaluate discrimination despite no timely Batson objection in trial court. | Reversed; Batson issue requires remand for proper trial-court findings. |
| Whether the remand order required specific trial-court findings on race/gender neutrality | The remand required trial court findings on whether reasons were race- and gender-neutral and whether discrimination occurred. | Trial court’s earlier rationale should suffice under the remand directives. | Remanded for explicit findings on race-neutral and gender-neutral reasons and the defendant’s discrimination burden. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (three-step Batson framework for peremptory challenges)
- J.E.B. v. Alabama, 511 U.S. 127 (U.S. 1994) (prohibits gender-based peremptory challenges)
- Hernandez v. New York, 500 U.S. 352 (U.S. 1991) (three-step Batson inquiry and trial-court credibility role)
- Ex parte Walker, 972 So.2d 737 (Ala. 2007) (Ala. plain-error framework for Batson-type claims)
- United States v. Dobynes, 905 F.2d 1192 (8th Cir. 1990) (contemporaneous objection requirement and Batson timing)