State of Louisiana v. Johnny Lee Harris
217 So. 3d 255
| La. | 2016Background
- Johnny Lee Harris was convicted of attempted armed robbery after a jury trial and sentenced to 30 years at hard labor; the Third Circuit affirmed.
- During voir dire Harris’s counsel used peremptory strikes against white female jurors Joanne Guidroz, Carolyn Duplechain, and Kandace Quebedeaux; the State lodged "reverse-Batson" objections.
- Defense counsel offered facially race-neutral reasons for strikes (e.g., juror knew prosecutor, lived next to a sheriff’s deputy, appeared bonded with the prosecutor, had a convicted son).
- The trial court rejected two of the defense’s peremptory strikes (Duplechain and Quebedeaux), apparently conflating Batson steps and denying the strikes without explicitly resolving whether reasons were pretextual.
- The Louisiana Supreme Court granted certiorari, concluded the trial court merged Batson steps two and three and improperly shifted the burden to the proponent of the strikes, vacated the conviction and sentence, and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court properly handled the State’s reverse-Batson objections to defense peremptory strikes | State argued defense strikes suggested racial discrimination and the court reasonably rejected defense reasons | Harris argued the court conflated Batson steps, shifted burden to defense, and failed to determine purposeful discrimination | Court held the trial court erred by merging Batson steps two and three, shifting the burden to the proponent of the strike; reversed and remanded |
| Whether facially race-neutral explanations must be persuasive at step two | State treated inadequacy of explanations at step two as dispositive | Defense relied on Batson/Purkett: race-neutrality suffices at step two; persuasiveness is a step-three inquiry | Court reaffirmed that persuasiveness belongs to step three; trial court erred by terminating inquiry at step two |
| Whether the record showed purposeful discrimination warranting denial of strikes | State contended record supported a finding of discriminatory intent | Defense argued the court never made an explicit finding that reasons were pretextual | Court found no explicit finding of pretext on the record and reversed for failure to assess purposeful discrimination |
| Standard of review for trial-court Batson determinations | State urged deference to trial-court credibility and factual findings | Defense argued legal error precludes deference where Batson steps were conflated | Court held legal error (failure to conduct step-three analysis) defeats deference and requires remand |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (1986) (establishes three-step test forbidding race-based peremptory strikes)
- Purkett v. Elem, 514 U.S. 765 (1995) (race-neutral explanation need not be persuasive at step two; persuasiveness is assessed at step three)
- Miller–El v. Dretke, 545 U.S. 231 (2005) (step-three burden: opponent must prove purposeful discrimination; courts evaluate persuasiveness of justification)
- Foster v. Chapman, 136 S.Ct. 1737 (2016) (reiterates Batson three-step framework and endorses record-intensive step-three review)
- State v. Nelson, 85 So.3d 21 (La. 2012) (Louisiana decision reprimanding conflation of Batson steps and improper burden-shifting)
- State v. Green, 655 So.2d 272 (La. 1995) (recognizes the opponent of a strike bears the ultimate burden to prove racial motivation)