Mitchell Landis v. State, 143 So. 3d 974

Defendant Mitchell Landis was tried for trafficking in cocaine; during jury selection the State used a peremptory strike on an African‑American prospective juror who identified his occupation as a kitchen manager.
Defense counsel objected under Florida’s Batson/Melbourne framework and requested a race‑neutral reason; the State responded that restaurant work involves rampant personal drug use and it did not want such a person on the jury.
The trial court stated the State’s reason was "genuine" and allowed the strike; defense renewed objections but a white juror who managed family restaurants was later seated without objection.
The jury convicted Landis and he received a 20‑year sentence (including a 15‑year minimum mandatory); Landis appealed arguing the court failed to adequately evaluate genuineness of the proffered race‑neutral reason.
The Fourth District held the record lacked a legally sufficient genuineness inquiry: occupation alone was not shown to be a non‑pretextual reason, the State did not question the juror about drug views, and similarly situated non‑minority jurors went unchallenged.
Court reversed and remanded for new trial because the trial court’s determination that the strike was not pretextual was clearly erroneous under Melbourne and related precedents.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly found the State’s race‑neutral reason for a peremptory strike to be genuine under Melbourne	State: occupation (kitchen manager) is a legitimate, race‑neutral basis because restaurant employees are more exposed to drug use	Landis: occupation alone was unexplored; prosecutor failed to question juror; similarly situated white juror was not struck—reason was pretextual	Reversed: trial court did not conduct a sufficient genuineness inquiry; record insufficient to sustain strike

Melbourne v. State, 679 So. 2d 759 (Fla. 1996) (establishes three‑step Batson/Melbourne procedure and focus on genuineness of race‑neutral reason)
Slappy v. State, 522 So. 2d 18 (Fla. 1988) (lists nonexclusive factors suggesting pretext for peremptory strikes)
Murray v. State, 3 So. 3d 1108 (Fla. 2009) (genuineness inquiry may consider venire racial makeup, prior strikes, singling out, and similar circumstances)
Hayes v. State, 94 So. 3d 452 (Fla. 2012) (reversal where record lacks indication trial court considered totality of circumstances for genuineness)
Cobb v. State, 825 So. 2d 1080 (Fla. 4th DCA 2002) (occupation can be race‑neutral reason but may be suspect if not explored by questioning)
Nowell v. State, 998 So. 2d 597 (Fla. 2008) (reason equally applicable to unchallenged juror undermines genuineness)