106 So. 3d 966
Fla. Dist. Ct. App.2013Background
- Defendant convicted by jury of possession of cocaine and possession of drug paraphernalia.
- Appeal raised three issues, but court found merit only in the peremptory strike issue based on Melbourne v. State requirements.
- State struck three African-American jurors; defense objected and requested race-neutral explanations.
- Courts allowed each strike after finding the proffered reasons race-neutral, but no Melbourne genuineness analysis was conducted on the record.
- The trial court’s failure to perform the genuineness inquiry led to a reversal and remand for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Melbourne genuineness analysis was required | Stevenson | Stevenson | Remand for new trial required; Melbourne analysis failed |
Key Cases Cited
- Melbourne v. State, 679 So.2d 764 (Fla. 1996) (three-step peremptory-strike framework; step 3 evaluates pretext)
- Murray v. State, 8 So.3d 1108 (Fla. 2009) (applies Melbourne procedure in evaluating racial strikes)
- Hayes v. State, 94 So.3d 452 (Fla.2012) (step 3 requires trial court to ensure explanation is not pretext)