People v. Jones CA1/2, A152863M

In April 2015 defendant Robert Earl Jones Jr. was identified by victim Jessica Williams as one of two armed intruders who robbed her home, tied her, struck her with a gun and stole cash and marijuana; Jones was arrested nine days later and convicted of first‑degree robbery, burglary, and false imprisonment.
During jury selection the prosecutor used peremptory strikes to remove three of five African‑American prospective jurors (Rogers, Thompson, Winston); defense counsel lodged Batson/Wheeler objections after some strikes and the trial court denied relief.
The trial court found no prima facie group bias as to at least one early strike and treated other strikes after hearing the prosecutor’s reasons as having plausible, nondiscriminatory bases (e.g., repeated “I don’t know” answers; a juror who fell asleep).
Defense sought to impeach Williams with an unrelated 2003 prior false statement (admission to lying in a drug case) to suggest she would lie to protect her then‑boyfriend (Benitez); the trial court excluded that cross‑examination under Evidence Code §352.
On appeal Jones challenged the Batson/Wheeler rulings (arguing pattern and failure to require reasons for earlier strike) and the exclusion of impeachment evidence as violating confrontation and due process rights; the Court of Appeal affirmed.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Jones)	Held
1) Were the prosecutor's peremptory strikes racially discriminatory (Batson/Wheeler)?	Prosecutor had race‑neutral, case‑related reasons for strikes (juror inattentiveness/sleeping; juror gave many "I don't know" answers suggesting low engagement); two African‑American jurors remained on panel.	Struck a disproportionate number of African‑American jurors; trial court erred by not requiring reasons for an earlier strike (Rogers) and failed to scrutinize prosecutor's stated reasons.	Affirmed. Strike of Rogers was forfeited on appeal; the court found credible, nondiscriminatory reasons for excusing Thompson and Winston and deferred to the trial court's sincere, reasoned evaluation.
2) Did exclusion of cross‑examination about Williams's 2003 false statement violate the Sixth Amendment confrontation right or defendant's right to present a defense?	Exclusion was proper under Evid. Code §352: the prior incident was remote, collateral, risked confusing issues, and was cumulative given other impeachment avenues.	Prior lie was highly probative of motive to lie and collusion with Benitez; exclusion prevented effective impeachment and presentation of a third‑party culpability theory.	Affirmed. Exclusion did not violate Van Arsdall; the proffered impeachment was attenuated and would not have produced a significantly different impression of credibility; §352 ruling was within trial court discretion.

Batson v. Kentucky, 476 U.S. 79 (prohibition on race‑based peremptory strikes)
Wheeler v. California, 22 Cal.3d 258 (state constitutional rule against group‑based jury exclusion)
People v. Scott, 61 Cal.4th 363 (framework clarifying first‑ vs third‑stage Batson review)
People v. Avila, 38 Cal.4th 491 (scope of trial court duty to revisit earlier strikes when a prima facie case later appears)
Unzueta v. Akopyan, 42 Cal.App.5th 199 (trial court must elicit neutral reasons for each excusal once prima facie showing established)
Delaware v. Van Arsdall, 475 U.S. 673 (Confrontation Clause and the standard for when limiting cross‑examination violates confrontation)
People v. Frye, 18 Cal.4th 894 (trial court wide latitude to limit repetitive, prejudicial, or marginally relevant cross‑examination)
People v. Lenix, 44 Cal.4th 602 (defendant bears ultimate burden; appellate review deferential to trial court Batson rulings)
People v. McDermott, 28 Cal.4th 946 (timeliness of Batson/Wheeler motions and effect of alternates selection)
People v. Krebs, 8 Cal.5th 265 (analysis on whether to review first‑stage or proceed to third‑stage Batson inquiry)