People v. Beauvais, 393 P.3d 509

Background

Heather Beauvais was tried for felony stalking and related crimes; during jury selection the prosecutor used five of six peremptory challenges to remove women, resulting in a 9–3 male-female jury with a female alternate.
Beauvais raised Batson objections after the prosecutor’s third, fourth, and fifth strikes, asserting a prima facie gender-based pattern; the trial court found a prima facie case, required gender-neutral reasons, then overruled Batson after a recess.
The prosecutor offered multiple reasons for each strike (demeanor: appearing "disinterested," deadpan; non-demeanor: young, in college, no children, coughing/illness, family ties to law enforcement or stalking victims).
Beauvais contested pretext chiefly by pointing to similarly situated male jurors (young, childless, connections to law enforcement) and the prosecutor’s waiver of the final strike; she did not build a record on juror demeanor.
The court of appeals remanded for specific credibility findings, refused to credit demeanor-based reasons absent express findings (citing Snyder), and employed comparative juror analysis; the Colorado Supreme Court granted certiorari.
The Colorado Supreme Court reversed the court of appeals, holding (1) appellate review must defer to trial courts’ step‑three Batson findings if the record shows the trial court weighed pertinent circumstances, (2) express credibility findings are not always required (including for demeanor-based reasons), and (3) comparative juror analysis on appeal is permissible only where the record supports a reliable comparison and the empaneled juror shares the same characteristics relied on by the striking party.

Issues

Issue	Plaintiff's Argument (Beauvais)	Defendant's Argument (People)	Held
Whether appellate court properly remanded for express credibility findings on non‑demeanor reasons (age, college, childlessness, illness)	Trial court failed to make specific findings; record insufficient to credit prosecutor’s stated neutral reasons; remand required	Express findings on each non‑demeanor reason are not necessary; the trial court’s ultimate Batson ruling can implicitly credit reasons	Reversed remand: appellate courts should defer to trial court’s ultimate step‑three finding if the record shows the court weighed pertinent circumstances; express credibility findings not always required
Whether lack of express credibility findings for demeanor‑based reasons precludes appellate credit under Snyder	Snyder requires express findings to credit demeanor reasons; court of appeals properly refused to presume credibility	Snyder is fact‑specific; failure to make express findings about demeanor alone does not bar appellate deference where the record supports the trial court’s ruling	Trial court’s omission of explicit demeanor‑credibility findings does not, by itself, prevent a reviewing court from concluding the trial court credited those reasons; Snyder is limited to its facts
Proper scope and method of comparative juror analysis on appeal	Comparisons of traits (e.g., unwillingness to participate) show pretext because similar male jurors remained on panel	Comparative analysis may be used but only where the record allows reliable comparison and comparisons should match the specific traits relied upon by the striking party	Appellate courts may conduct comparative juror analyses raised for first time on appeal only if the record facilitates a reliable comparison; an empaneled juror is "similarly situated" only if he/she shares the same characteristics for which the challenged juror was struck; single‑trait comparisons insufficient when the proponent relied on a combination of traits

Key Cases Cited

Batson v. Kentucky, 476 U.S. 79 (forbids peremptory strikes based on race; three‑step Batson framework)
J.E.B. v. Alabama ex rel. T.B., 511 U.S. 127 (extends Batson to gender)
Snyder v. Louisiana, 552 U.S. 472 (2008) (demeanor‑based reasons require careful assessment; reversal where record refuted non‑demeanor reason and demeanor finding was not shown)
Foster v. Chatman, 136 S. Ct. 1737 (2016) (appellate review must consider all circumstantial evidence; comparative juror analysis can expose pretext)
Miller‑El v. Dretke, 545 U.S. 231 (2005) (comparative juror analysis and circumstantial evidence relevant to pretext)
Hernandez v. New York, 500 U.S. 352 (1991) (credibility and demeanor determinations lie ‘‘peculiarly within a trial judge’s province’’)
Purkett v. Elem, 514 U.S. 765 (1995) (burden remains on objector; implausible justifications may be pretext)