State of Iowa v. Marquise D. Miller, 16-0331

Marquise Miller, a Black defendant, was convicted of eluding, second-degree theft, and accessory after the fact; he appealed alleging Batson error and the convictions were reversed and remanded.
During voir dire the prosecutor used two of six peremptory strikes to remove the only two Black prospective jurors.
The first struck juror disclosed a traumatic negative experience with law enforcement (granddaughter killed by an off-duty officer); the State moved to strike for cause, was denied, then used a peremptory strike citing the juror’s negative law‑enforcement experience.
The second struck juror said she knew one officer socially and remarked “They’re okay. There’s always room for improvement.” The State struck her, citing that response and her demeanor.
Defense raised a Batson challenge; the trial court accepted the State’s race‑neutral explanations and denied relief. On appeal the Court of Appeals reviewed the Batson claim de novo.
The appellate court found the State’s explanations insufficient in light of (1) the pattern of striking the only two Black venire members, (2) similarly negative (or more negative) law‑enforcement statements from non‑Black jurors who were not struck, and (3) the prosecutor’s failure to explore the second juror’s views further — and reversed and remanded for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the prosecutor’s peremptory strikes violated Batson (racial discrimination in jury selection)	State: strikes were race‑neutral — first juror struck for clear negative law‑enforcement experience; second juror struck for a pointed comment and demeanor indicating bias against law enforcement	Miller: strikes targeted the only Black jurors; explanations were pretextual because similarly situated non‑Black jurors with negative law‑enforcement views were not struck and prosecutor didn’t probe the second juror	Court: Reversed — State’s reasons were not convincing; pattern and comparators showed pretext and Batson violation; new trial ordered

Batson v. Kentucky, 476 U.S. 79 (prohibits race‑based peremptory strikes)
Powers v. Ohio, 499 U.S. 400 (defendant need not be same race as excluded juror to raise Batson)
Snyder v. Louisiana, 552 U.S. 472 (demeanor‑based explanations require court’s credibility assessment)
Miller‑El v. Cockrell, 537 U.S. 322 (patterns of strikes can demonstrate discrimination)
Miller‑El v. Dretke, 545 U.S. 231 (defendant may rely on all relevant circumstances beyond the case to show pretext)
State v. Mootz, 808 N.W.2d 207 (Iowa Batson framework—three‑step analysis)
State v. Knox, 464 N.W.2d 445 (consider all relevant circumstances including pattern and voir dire)
State v. Griffin, 564 N.W.2d 370 (Iowa reviews constitutional challenges de novo)
State v. Bessenecker, 404 N.W.2d 134 (Iowa limits prosecutor access to jurors’ criminal rap sheets)