People v. Hecker
15 N.Y.3d 625
| NY | 2010Background
- The Batson three-step framework governs challenges alleging racial discrimination in jury selection.
- The opinion analyzes four cases (Hecker, Guardino, Hollis, Black) under Batson, focusing on step one (prima facie showing) and step two/three in some, with Hecker reversed for a new trial.
- In Hecker, Chan and Lee were jurors challenged; Lee’s voir dire raised questions about unconscious bias and the court’s questioning; Chan was struck based on perceived demeanor and limited questioning time.
- Guardino and Hollis centers on whether the People’s peremptory strikes created a cognizable discrimination pattern; Guardino held no prima facie case; Hollis likewise rejected renewal and found no prima facie case.
- Black involved race-neutral reasons for striking jurors Gordon, Williams, and Thomas; the court upheld the People’s reasons and affirmed conviction, with deference to trial court credibility findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Guardino step-one prima facie adequacy | Defense showed a pattern against black females. | Numerical data alone insufficient; no cognizable pattern shown. | No valid prima facie showing; Batson not established. |
| Hollis step-one prima facie adequacy | Numbers demonstrated discrimination in round two. | No prima facie case at that juncture; renewal permitted but not pursued. | No prima facie case; Batson not established. |
| Hecker step-two/three proceedings and pretext finding | Chan’s strike was race-based; Lee’s questioning showed bias against defense. | Reasons were race-neutral and tied to trial strategy; no pretext. | Court reversed and ordered a new trial for Hecker; step-three finding of pretext rejected; remanded. |
| Automatic reversal for erroneous denial of peremptory challenge | Peremptory challenges denied incorrectly require automatic reversal. | Rivera state-law approach allows discretionary review; no automatic reversal mandated. | New York law requires automatic reversal for erroneous denial of a peremptory challenge. |
| Black assessment of race-neutral reasons (step-two/three) | Reasons largely neutral and tied to voir dire conduct and qualifications. | Reasons justified by demeanor and educational/employment factors. | Court upheld race-neutral reasons and affirmed conviction; no pretext determined. |
Key Cases Cited
- Batson v. Kentucky, 476 US 79 (Supreme Court, 1986) (three-step test for racial discrimination in peremptory challenges)
- Hernandez v. New York, 500 US 352 (Supreme Court, 1991) (race-neutral explanations required at step two)
- Allen v. State, 86 NY2d 101 (New York Court of Appeals, 1995) (acknowledges Batson framework and step-two burden)
- Smocum v. People, 99 NY2d 418 (New York Court of Appeals, 2003) (mootness doctrine after race-neutral reasons are offered)
- Payne v. People, 88 NY2d 172 (New York Court of Appeals, 1996) (step-three pretext inquiry and ultimate burden on movant)
- Purkett v. Elem, 514 US 765 (Supreme Court, 1995) (pretext may be identified from implausible reasons)
- Miller-El v. Cockrell, 537 US 322 (Supreme Court, 2003) (deference to trial court on credibility and demeanor)
- Johnson v. California, 545 US 162 (Supreme Court, 2005) (first-step burden not onerous; totality of circumstances matters)