People v. Rodriguez, 351 P.3d 423

Defendant Romielo Rodriguez was tried on felony menacing charges; during jury selection the prosecutor used peremptory strikes to remove two minority prospective jurors (Ms. D., a black woman; Ms. A., a Hispanic‑surname woman).
Rodriguez objected under Batson v. Kentucky, but the trial court denied both Batson challenges without eliciting detailed race‑neutral explanations, stating that a "pattern" of strikes was necessary to succeed.
The prosecutor relied on limited justifications on the record (Ms. D. "feels there is mistaken identity all the time"; Ms. A. had written on her questionnaire that she could not be fair "because of my religious beliefs") and did not question Ms. A. about that answer in voir dire.
Rodriguez was convicted; on appeal the Colorado Court of Appeals found Batson violations and ordered a new trial, treating the trial court’s inadequate Batson inquiry as requiring automatic reversal.
The Colorado Supreme Court granted certiorari to decide the proper remedy when a trial court conducts an inadequate Batson inquiry and whether reversal was required in this case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a pattern of strikes is required to make a Batson prima facie case	People: Trial court erred but no Batson violation; pattern is a relevant factor	Rodriguez: Pattern not required; single strikes may give rise to inference of discrimination	Held: Pattern is relevant but not required; trial court erred by treating pattern as dispositive
Proper remedy when the trial court’s Batson inquiry is inadequate	People: Remand for the trial court to conduct the full three‑step Batson analysis	Rodriguez: Insufficient record; passage of time makes meaningful remand inadequate — reversal/new trial warranted	Held: Remand to trial court for full Batson findings and analysis is the proper remedy; not automatic reversal

Batson v. Kentucky, 476 U.S. 79 (1986) (establishes three‑step test prohibiting race‑based peremptory strikes)
Miller‑El v. Cockrell, 537 U.S. 322 (2003) (prima facie showing step explained)
Miller‑El v. Dretke, 545 U.S. 231 (2005) (evaluating credibility and pretext at step three)
Purkett v. Elem, 514 U.S. 765 (1995) (low bar for race‑neutral explanations at step two)
Snyder v. Louisiana, 552 U.S. 472 (2008) (Court’s deference to trial judge on credibility at step three; even a single discriminatory strike forbidden)
Johnson v. California, 545 U.S. 162 (2005) (Batson framework designed to elicit actual answers to discrimination suspicions)
Valdez v. People, 966 P.2d 587 (Colo. 1998) (Colorado discussion of Batson steps and relevant circumstances)
United States v. Vasquez‑Lopez, 22 F.3d 900 (9th Cir. 1994) (pattern of strikes not required to establish Batson prima facie case)