State v. Aziakanou, 498 P.3d 391

Officers surveilled Pioneer Park and observed Ayayai Aziakanou repeatedly approach passersby and lead them to a companion; officers watched at least three money-for-canister exchanges and recovered canisters containing spice.
Aziakanou was arrested and charged with distribution of or arranging to distribute a controlled substance (third-degree felony); case proceeded to a one-day jury trial.
During voir dire Juror 13 (the only apparent person of color in the panel) recounted repeated stops he viewed as racial profiling but stated he would be fair and decide based on the evidence.
The State used a peremptory strike on Juror 13; defense raised a Batson challenge alleging purposeful race-based exclusion; court allowed the prosecutor to explain the strike and overruled Batson.
Aziakanou moved for a directed verdict after the State rested; the court denied the motion. Aziakanou was convicted and appealed, challenging the Batson ruling and sufficiency of the evidence.
The Utah Supreme Court affirmed, finding the prosecutor’s reason facially race-neutral (concern juror would discredit police testimony) and the evidence sufficient to support the conviction.

Issue	Plaintiff's Argument (Aziakanou)	Defendant's Argument (State)	Held
Whether the State violated Batson by peremptorily striking Juror 13	Strike was motivated by race; juror’s experience of racial profiling is not a race-neutral basis for removal	Strike was race-neutral: prosecutor reasonably believed juror’s prior negative experiences and demeanor indicated bias against law‑enforcement witnesses	Court held the prosecutor’s proffer was facially race‑neutral and the trial court did not clearly err in crediting it; Batson challenge denied
Whether evidence was sufficient to sustain conviction for distribution or arranging to distribute spice	No direct proof of intent or statements arranging sales; evidence too speculative	Circumstantial evidence (repeated approach-lead-observe pattern, recovered canisters, spice on a purchaser) supports an inference of arranging/distribution	Court held circumstantial evidence was sufficient; directed verdict denial and conviction affirmed

Batson v. Kentucky, 476 U.S. 79 (prohibits race-based peremptory strikes; establishes three-step Batson inquiry)
Flowers v. Mississippi, 139 S. Ct. 2228 (2019) (factors courts may consider at Batson step three; trial judges’ front-line role)
Hernandez v. New York, 500 U.S. 352 (1991) (step-two focus on facial race-neutrality; assume proffered reasons true for analysis)
Purkett v. Elem, 514 U.S. 765 (1995) (step-two does not require persuasive or plausible reasons)
Johnson v. California, 545 U.S. 162 (2005) (prima facie showing standard for Batson step one)
Felkner v. Jackson, 562 U.S. 594 (2011) (per curiam) (reference to prior‑experience concerns in recitation of facts)
Powers v. Ohio, 499 U.S. 400 (1991) (standing to challenge race‑based exclusion on behalf of excluded jurors)
Georgia v. McCollum, 505 U.S. 42 (1992) (peremptory challenges can constitute state action; courts/State may vindicate excluded jurors’ rights)
State v. Colwell, 994 P.2d 177 (Utah 2000) (Batson step-one discussion in Utah law)
State v. Cantu, 778 P.2d 517 (Utah 1989) (Utah formulation of factors for proffered reasons for peremptory strikes)