State of Missouri v. Roscoe R. Meeks, 2016 Mo. LEXIS 277

Defendant Roscoe Meeks, an African-American, was tried for first-degree assault and armed criminal action after victim (a Mexican native) was shot; eyewitnesses and an in-person lineup identified Meeks.
Voir dire produced an overtly racist remark by Venireperson A; a member of the venire reportedly responded aloud, "let’s open that can." The prosecutor moved to strike some jurors in that row.
The prosecutor used peremptory strikes, including strikes of Venireperson H (white) and Venireperson C (stipulated to be African‑American). Defense counsel raised a Batson challenge to the strike of Venireperson C.
At the Batson hearing, the prosecutor explained she wanted to exclude anyone in the row who reacted to the racist remark and, because she had one strike left, she "made my bets" that the defense would strike Venireperson D (white) so she struck Venireperson C (African‑American).
The trial court found the prosecutor’s explanations race‑neutral, denied the Batson challenge, and Meeks was convicted by a jury (10 white, 1 African‑American, 1 unknown).
On appeal the Missouri Supreme Court reviewed whether the prosecutor offered a "reasonably specific and clear race‑neutral" explanation for the strike; it held she did not and vacated Meeks’ convictions and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prosecutor provided a reasonably specific, race‑neutral explanation for striking Venireperson C under Batson/Parker	Meeks: prosecutor failed step two — offered either an explicitly race-based rationale or an unexplained strategic belief, so no objectively race‑neutral reason was given	State: prosecutor’s stated strategy and contemporaneous explanations suffice; any ambiguity is harmless and one explanation was nonracial	Court: Reversed — prosecutor failed to offer a reasonably specific, race‑neutral explanation for striking Venireperson C; Batson violation required vacatur and remand

Batson v. Kentucky, 476 U.S. 79 (1986) (prohibits race‑based peremptory strikes and establishes burden‑shifting framework)
Purkett v. Elem, 514 U.S. 765 (1995) (second‑step explanation need not be persuasive or plausible if not inherently discriminatory)
Hernandez v. New York, 500 U.S. 352 (1991) (courts must assess whether proffered reasons, assumed true, violate Equal Protection as a matter of law)
Rice v. Collins, 546 U.S. 333 (2006) (appellate review of Batson credibility findings limited)
State v. Parker, 836 S.W.2d 930 (Mo. banc 1992) (adopted three‑step Batson procedure for Missouri; prosecutor must give reasonably specific, clear race‑neutral reasons)
State v. Bateman, 318 S.W.3d 681 (Mo. banc 2010) (trial/appellate courts may only consider explanations actually offered by prosecutor at trial)
State v. Carter, 415 S.W.3d 685 (Mo. banc 2013) (race‑neutrality at step two judged objectively; disparate impact not dispositive)