Floyd v. State
190 So. 3d 987
Ala. Crim. App.2012Background
- Remand from Alabama Supreme Court directed trial court to make factual and legal findings on whether State’s strikes of African-American jurors were race-neutral and whether strikes of female jurors were gender-neutral, and whether Floyd proved purposeful discrimination.
- Trial court conducted Batson/J.E.B. analysis in three steps and found race- and gender-neutral reasons; Floyd argued pretext and discriminatory intent.
- Alabama Supreme Court on remand affirmed trial court’s broad authority to evaluate demeanor and credibility of the State’s explanations and to defer to trial court findings in step three.
- Court on remand noted Floyd’s prior prima facie showing of discrimination and that the State provided race- and gender-neutral reasons for strikes.
- Trial court concluded the State’s reasons were not pretextual and Floyd failed to prove discriminatory intent; conviction and death sentence affirmed.
- Record shows the second remand hearing evaluated multiple jurors, with detailed enumerations of the State’s asserted reasons for each strike and the defense’s rebuttals.
- Court reiterated deference to trial court’s credibility determinations in evaluating discriminatory intent under Batson.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether State’s reasons for striking African-American jurors were race-neutral | Floyd asserts pretext and discriminatory intent. | State-proffered reasons are facially race-neutral. | Yes; reasons race-neutral; no proof of purposeful discrimination. |
| Whether State’s reasons for striking female jurors were gender-neutral | Floyd argues pretext and gender-based discrimination. | State-proffered reasons are facially gender-neutral. | Yes; reasons gender-neutral; no proof of purposeful discrimination. |
| Whether the trial court’s Batson/J.E.B. determination was clearly erroneous | Trial court erred in crediting State’s explanations as non-pretextual. | Trial court properly weighed credibility and demeanor of counsel and jurors. | No; ruling not clearly erroneous; affirm Batson/J.E.B. denial. |
| Whether deference to trial court’s findings is appropriate | Deference should not excuse pretext. | Trial court’s credibility determinations deserve deference. | Yes; appellate review deferential, not reversing absent clear error. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (1986) (establishes a three-step inquiry for peremptory challenges)
- Hernandez v. New York, 500 U.S. 352 (1991) (race-neutral explanation; credibility of state of mind lies with trial judge)
- Ex parte Branch, 526 So.2d 609 (Ala.1987) (trial court assess sham or pretext for discriminatory claims)
- Miller-El v. Cockrell, 537 U.S. 322 (2003) (framework for evaluating race-neutral explanations)
- Purkett v. Elem, 514 U.S. 765 (1995) (pretext and credibility in Batson step three)
- Jackson v. State, 169 So.3d 1 (Ala.Crim.App.2013) (application of race-neutral reasons including knowledge of jurors)
- Smith v. State, 838 So.2d 413 (Ala.Crim.App.2002) (race-neutral reasons for strikes like religious beliefs or demeanor)
- Riley v. State, 166 So.3d 705 (Ala.Crim.App.2013) (deference to trial court on discriminatory-intent findings)