Maria N. Vinson v. Koch Foods of Alabama, LLC, 12f4th1270

Background

Vinson, a Puerto Rican former Koch Foods HR clerk/translator, was suspended after leaving the HR office with coworkers to visit a hospitalized colleague; she later was moved to the production line and then terminated in May 2012.
Vinson sued Koch and manager David Birchfield for race and national-origin discrimination under §1981 and Title VII; Birchfield was voluntarily dismissed with prejudice before trial.
The district court empaneled a 10-member jury (no alternates) from a 23-person venire that included at least nine Black prospective jurors; each side had three peremptory strikes.
Koch used all three peremptory strikes on Black jurors (Jurors 9, 16, 32); Vinson challenged two of those strikes (Jurors 9 and 32) under Batson.
During trial Vinson introduced Exhibit 57 (requests for production naming Koch and Birchfield). Koch counsel then questioned Birchfield’s former-party status and asked the court to take judicial notice he was a “prevailing party,” prompting Vinson’s motion for mistrial; the court denied mistrial and later denied a new-trial motion after a Koch verdict.
On appeal Vinson argued (1) the district court erred in overruling her Batson challenges to peremptory strikes of Jurors 9 and 32, and (2) counsel’s reference to Birchfield as a “prevailing party” violated the in limine order and warranted a new trial; the Eleventh Circuit affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Batson challenge to strike of Juror 9	Koch struck Juror 9 because she was Black and Koch did not individually question her; pattern of strikes and disparate questioning establish prima facie case	Koch had pretrial background research showing Juror 9 had extensive civil litigation history and debt-collection suits, a race-neutral reason	Court found a prima facie case but credited Koch’s litigation-history explanation as race-neutral and not pretextual; Batson challenge overruled
Batson challenge to strike of Juror 32	Pattern of strikes against Black jurors supports prima facie case; Koch’s reasons were pretextual	Koch individually questioned Juror 32 and discovered she was a union member and prior worker’s-comp claimant with reservations about fairness—race-neutral reasons to strike	Even if prima facie established, court found Koch’s union/worker’s-comp explanation plausible and not pretextual; Batson challenge overruled
Motion for mistrial / new trial based on in limine violation	Koch counsel’s calling Birchfield a “prevailing party” violated the in limine order and prejudiced the jury, warranting mistrial or new trial	Vinson opened the door by introducing Exhibit 57 (which named Birchfield); the remark was brief, the court denied the judicial-notice request, and appropriate curative instructions could have been given	Court did not abuse discretion denying mistrial/new trial: Vinson opened the door, the remark was brief and context limited, and no gravely prejudicial effect shown

Key Cases Cited

Batson v. Kentucky, 476 U.S. 79 (prohibits race-based peremptory strikes and establishes three-step Batson framework)
Snyder v. Louisiana, 552 U.S. 472 (describes Batson burden-shifting and trial-court credibility role)
Flowers v. Mississippi, 139 S. Ct. 2228 (emphasizes deference to trial court on discriminatory intent findings)
Ruiz v. Wing, 991 F.3d 1130 (11th Cir.) (abuse-of-discretion standard for mistrial/new-trial claims)
Cote v. R.J. Reynolds Tobacco, 909 F.3d 1094 (11th Cir.) (trial-court vantage and deference in assessing counsel misconduct and prejudice)
U.S. v. Walker, 490 F.3d 1282 (11th Cir.) (explains the low bar for race-neutral explanations for peremptory strikes)
McGahee v. Ala. Dept. of Corr., 560 F.3d 1252 (11th Cir.) (permissible to consider for-cause strikes when evaluating Batson prima facie showing)
Hernandez v. New York, 500 U.S. 352 (credibility determinations on Batson are for the trial judge)