395 S.W.3d 192
Tex. App.2012Background
- Haynes, a car inspector at Strang Yard, sues Union Pacific under FELA for injuries when a railcar struck his vehicle on leaving the yard.
- After a jury trial, Haynes is awarded $456,300 plus interest; both sides appeal.
- Haynes challenges Union Pacific’s use of peremptory strikes, claiming a Batson violation (racial discrimination).
- Trial court assumed a prima facie case of discrimination given four of six black venire members were struck.
- Union Pacific offered race-neutral explanations for the strikes; the court overruled the Batson challenge.
- Court holds Batson challenge as to Juror No. 3 was sustained, reverses and remands for a new trial; other issues not addressed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Batson challenge to peremptory strikes | Haynes argues UP used race in striking jurors. | UP asserts race-neutral explanations for strikes. | Batson challenge sustained as to Juror No. 3; remand for new trial. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (1986) (racial discrimination in peremptory strikes violates equal protection)
- Edmonson v. Leesville Concrete Co., 500 U.S. 614 (1991) (extending Batson to civil trials)
- Miller-El v. Dretke (Miller-El II), 545 U.S. 231 (2005) (burden-shifting framework and pretext analysis for Batson challenges)
- Purkett v. Elem., 514 U.S. 765 (1995) (race-neutral explanations need not be persuasive but must be non-discriminatory)
- Goode v. Shoukfeh, 943 S.W.2d 441 (Tex. 1997) (Texas Supreme Court on Batson procedures and credibility of explanations)
- Snyder v. Louisiana, 552 U.S. 472 (2008) (reversal when nonrecorded demeanor explanations lack support)
- Davis v. Fisk Elec. Co., 268 S.W.3d 508 (Tex. 2008) (review of Batson under totality of circumstances; preservation of ultimate burden)