State of Florida v. Geovani Johnson, 295 So.3d 710

The Fourth District reversed a conviction in Johnson v. State, holding the trial court failed to make a record demonstrating it independently evaluated the genuineness of a race-neutral reason for a peremptory strike under Melbourne.
Melbourne established a three-step Batson framework in Florida: (1) timely objection and request for a race-neutral reason; (2) proponent must articulate a facially race-neutral reason; (3) court determines genuineness (focus on genuineness, not reasonableness).
At trial the State peremptorily struck an African-American prospective juror; Johnson requested a race-neutral reason and the State said the juror preferred “CSI evidence.” The trial court accepted the reason after a brief exchange; Johnson did not specifically contest the factual support or genuineness at that time.
On appeal the Fourth DCA (relying on Spencer and language in Hayes) held Johnson’s initial request preserved a later challenge to genuineness and reversed for lack of an on-the-record step-3 inquiry, certifying conflict with Ivy, Hanna, and Brown.
The Florida Supreme Court quashed the Fourth DCA decision, reaffirming Floyd and holding that to preserve a challenge to the trial court’s step-3 genuineness finding the opponent must contemporaneously make a specific objection contesting the proponent’s race-neutral reason.

Issue	Johnson's Argument	State's Argument	Held
Does a general request for a race-neutral reason at Melbourne step 1 preserve a later challenge to the reason’s genuineness at step 3?	A step-1 request suffices; trial court must create a record showing it evaluated genuineness.	Johnson failed to preserve because he never specifically contested the proffered reason’s factual support or genuineness at trial.	Preservation requires a specific, contemporaneous objection contesting the proffered race-neutral reason’s genuineness; mere request at step 1 is insufficient.
Is the trial court required to undertake an on-the-record genuineness inquiry sua sponte even when the opponent remains silent?	Hayes/Spencer suggest courts must conduct an on-the-record genuineness inquiry regardless of opponent’s silence.	Those statements are dicta and inconsistent with Floyd; no automatic duty to create such a record when opponent does not contest the proffered reason.	Disapproved of Hayes dicta relied on by Spencer; reaffirmed Floyd — trial judges may probe sua sponte but are not required to create an on-record step-3 inquiry if the opponent did not contest the proffered reason.

Melbourne v. State, 679 So. 2d 759 (Fla. 1996) (establishing Florida’s three-step framework for reviewing peremptory strikes)
Floyd v. State, 569 So. 2d 1225 (Fla. 1990) (preservation rule: opponent must place court on notice when challenging proponent’s factual assertions)
Johnson v. State, 268 So. 3d 729 (Fla. 4th DCA 2018) (Fourth DCA decision under review reversing for insufficient on-record step-3 inquiry)
Spencer v. State, 238 So. 3d 708 (Fla. 2018) (plurality relying on Hayes language to require on-record genuineness inquiry)
Hayes v. State, 94 So. 3d 452 (Fla. 2012) (language suggesting trial courts should undertake on-the-record genuineness inquiry; treated as dicta here)
Ivy v. State, 196 So. 3d 394 (Fla. 2d DCA 2016) (conflicting DCA decision on preservation)
Hanna v. State, 194 So. 3d 424 (Fla. 3d DCA 2016) (conflicting DCA decision on preservation)
Brown v. State, 204 So. 3d 546 (Fla. 5th DCA 2016) (conflicting DCA decision on preservation)
Dorsey v. State, 868 So. 2d 1192 (Fla. 2003) (noting objecting party must place trial court on notice and create record)
Rimmer v. State, 825 So. 2d 304 (Fla. 2002) (same preservation principle reaffirmed)