207 So. 3d 1282
Miss. Ct. App.2016Background
- Payne was convicted of robbery in Lamar County Circuit Court and sentenced to 15 years MDOC.
- The State’s peremptory strikes were challenged under Batson during voir dire; the trial court found a pattern against minorities and required race-neutral reasons.
- The trial court upheld a Batson challenge against juror nineteen, but denied it for juror twenty and sustained against juror twenty-two.
- The State provided race-neutral explanations for strikes on jurors including juror twenty, which the court deemed insufficient; the third strike against African Americans was not supported.
- Payne’s Batson challenge was denied on appeal; he also argued that closing-argument remarks requiring him to take responsibility warranted a mistrial, which the court rejected.
- The Court affirmed Payne’s conviction and sentence, holding no reversible error was shown.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Batson challenge on jurors twenty and twenty-two | Payne | Payne | Batson challenge denied on juror twenty; denied for juror twenty-two (no error overall) |
| Mistrial due to closing remarks | Payne | Payne | No reversible error; remarks insufficient to mandate mistrial given overwhelming evidence |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (1986) (prohibits race-based peremptory strikes)
- Lynch v. State, 877 So.2d 1254 (Miss. 2004) (three-prong Batson analysis; deference to trial court on race-neutral reasons)
- Perry v. State, 949 So.2d 764 (Miss. Ct. App. 2006) (great deference to trial court on race-neutral explanations)
- Randall v. State, 716 So.2d 584 (Miss. 1998) (race-neutral reasons need not be persuasive or plausible)
- Lockett v. State, 517 So.2d 1346 (Miss. 1987) (living in a high-crime area as a race-neutral reason)