State of Iowa v. Jerin Douglas Mootz
808 N.W.2d 207
Iowa2012Background
- Mootz was convicted of assault on a police officer resulting in bodily injury under Iowa Code 708.3A.
- During voir dire Mootz sought to strike a Hispanic juror; the district court found possible racial discrimination and seated the juror instead.
- Before strike attempts, the court indicated Ramirez (Hispanic) could be stricken but Garcia (also Hispanic) could not; Mootz struck Ramirez.
- The court sua sponte conducted a Batson inquiry, found Mootz’s stated reasons for striking Garcia insufficient, and did not permit the strike against Garcia, leaving Garcia as a juror.
- Mootz moved for mistrial; the district court denied, citing the need for a fair panel including minority representation; Mootz was later convicted.
- The court of appeals affirmed the conviction; this court reversed and remanded for a new trial, finding error in the Batson analysis and remedy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court erred denying Mootz’s peremptory strike | Mootz argues strikes cannot be used to discriminate; valid race-neutral reasons exist. | Mootz contends Garcia’s removal was proper to protect his fair trial rights and avoid bias. | Yes; district court erred by prohibiting the strike based on discriminatory intent analysis. |
| Whether the Batson issue could be raised sua sponte | State may raise sua sponte to protect juror equal protection rights. | Trial court should wait for objection; sua sponte should be limited to clear prima facie cases. | Court may raise sua sponte but must observe a clear prima facie case and provide adequate record. |
| Whether Mootz offered race-neutral reasons for striking Garcia and whether they were legitimate | Reasons (police interactions and bartender experience) were race-neutral and legitimate. | Reasoning may be pretextual; trial court should assess credibility and ultimate discriminatory intent. | Reasons were race-neutral and legitimate; trial court erred by rejecting them without proper step-three analysis. |
| What remedy applies for wrongful denial of a peremptory strike | Automatic reversal is appropriate because prejudice is presumed when a peremptory is denied. | Neuendorf requires showing actual prejudice; automatic reversal is not required. | Automatic reversal; rule 2.18(9) mandates reversal when denial of a peremptory strike leads to an objectionable juror seated. |
| Does Neuendorf govern the remedy in Mootz’s case distinguishing from Reed/Beckwith | Neuendorf supports no automatic prejudice presumption in other contexts, but Mootz’s juror sat, so remedy should be automatic. | Remedy depends on whether the juror seated was impartial; Neuendorf previously limited prejudice presumption. | Remedy automatic reversal; Mootz entitled to new trial due to erroneous denial of peremptory strike. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (three-step Batson framework for racial discrimination in peremptory strikes)
- Purkett v. Elem, 514 U.S. 765 (U.S. 1995) (clarifies step-two race-neutral explanation; burden shifts to showing discrimination at step three)
- Hernandez v. New York, 500 U.S. 352 (U.S. 1991) (prima facie case and mootness of preliminary issue after race-neutral explanation)
- Rivera v. Illinois, 556 U.S. 148 (U.S. 2009) (peremptory-strike denial not structural error; states determine remedy; but allows sua sponte Batson inquiry with safeguards)
- State v. Neuendorf, 509 N.W.2d 743 (Iowa 1993) (rejected automatic prejudice presumption when defendant forced to waste a peremptory strike for cause error)
- Beckwith v. State, 242 Iowa 228 (Iowa 1951) (presumption of prejudice when peremptory strike used to correct cause challenge error)
- Reed v. State, 201 Iowa 1352 (Iowa 1926) (prejudice presumed when cause challenge erroneously denied and peremptory used to remove juror)
- Summy v. City of Des Moines, 708 N.W.2d 333 (Iowa 2006) (limits on remedy when error involves statutory peculiarities (section 624.11A) in jury selection)
- Holland v. Illinois, 493 U.S. 474 (U.S. 1990) (peremptory challenges carry traditional role in jury selection)