Mitchell Carroll v. State of Indiana (mem. dec.), 27A02-1606-CR-1536

Mitchell Carroll was charged with multiple felonies and misdemeanors after a July 2015 incident in which he allegedly kidnapped and threatened A.N., brandished a rifle at police, and shell casings at his residence matched the rifle found in his car.
The trial court dismissed two charges; jury trial on the remaining twelve counts in May 2016 resulted in convictions and an aggregate 30‑year sentence.
During voir dire, two prospective jurors were African‑American; the State used peremptory strikes to remove both (one identified as R.J.).
R.J. stated during voir dire that she was "like a very, kind of psychic person," which the State cited as its race‑neutral reason for striking her.
Carroll objected under Batson; the trial court found the State’s explanation for R.J. credible and denied the Batson challenge. Carroll raised a Batson claim on appeal as to R.J. and an alleged second removed African‑American juror.
The appellate record contained inaudible portions regarding the second juror; Carroll did not supply a verified statement under Appellate Rule 31, so the record was inadequate to review that claim.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Carroll)	Held
Whether the State’s peremptory strike of R.J. violated Batson	Strike was race‑neutral because R.J. said she was "psychic," suggesting potential bias or inability to follow evidence/reasonable doubt standard	Strike was racially motivated because R.J. was African‑American; Batson objection warranted	Court: No Batson violation as to R.J.; State’s explanation was race‑neutral and the trial court reasonably credited it
Whether an alleged second African‑American juror was struck in violation of Batson	(Not fully developed due to record gaps)	Batson challenge to second strike should be reviewed and reversal/remand required	Court: Claim waived for appeal because Carroll failed to provide an adequate record or a verified statement under App. R. 31

Batson v. Kentucky, 476 U.S. 79 (1986) (established three‑step test prohibiting race‑based peremptory strikes)
Cartwright v. State, 962 N.E.2d 1217 (2012) (explains Batson three‑step framework and deference to trial court credibility findings)
Addison v. State, 962 N.E.2d 1202 (2012) (exclusion of a sole juror based on race violates Equal Protection)
McCormick v. State, 803 N.E.2d 1108 (2004) (race‑neutral explanation is any reason based on something other than race)
Wilhoite v. State, 7 N.E.3d 350 (2014) (appellant bears burden to supply an adequate record for appellate review)
Weekly v. State, 496 N.E.2d 29 (1986) (Batson challenge can be waived on appeal if the record is inadequate)