State v. Giles, 407 S.C. 14

Giles was convicted of first-degree burglary, strong-arm robbery, and kidnapping; sentences run concurrently (30, 30, 15 years).
Giles represented himself at trial with standby counsel.
During jury selection, Giles struck 8 white males and 2 white females with peremptory challenges.
The State invoked Batson to require a race-neutral justification; the State argued Giles’ reason was not race-neutral and the judge found it pretextual.
The trial court ultimately granted the Batson motion and quashed the jury panel; a new panel was selected.
The Court of Appeals affirmed; the issue is whether the trial court properly followed Batson’s three-step process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly applied Batson’s three-step process	Giles argues the court should have moved to step three	State contends the explanation was not sufficient to move to step three	No; failure to move to step three was correct; Batson step two was not satisfied with a clear, specific reason

Batson v. Kentucky, 476 U.S. 79 (U.S. Supreme Court, 1986) (establishes three-step Batson framework for peremptory challenges)
Purkett v. Elem, 514 U.S. 765 (U.S. Supreme Court, 1995) (clarifies step-two explanation need not be persuasive; focus on step three)
Miller-El v. Dretke, 545 U.S. 231 (U.S. Supreme Court, 2005) (reaffirms not needing persuasive step-two justification; emphasis on step-two clarity and step-three evaluation)
State v. Adams, 322 S.C. 114, 470 S.E.2d 366 (S.C. 1996) (Adams rejects broad Batson relief; later overruled to require reasonably specific second-step explanations)
Moeller v. Blanc, 276 S.W.3d 656 (Tex.App.2008) (post-Purkett on sufficiency of second-step justification)
Robinson v. U.S., 878 A.2d 1273 (D.C. Cir. 2005) (prosecutor’s vague reasons insufficient for clear, reasonably specific explanation)
Alex v. Rayne Concrete Svc., 951 So.2d 138 (La. 2007) (gut-feeling alone is insufficient; must be clear and reasonably specific)