State v. Inman
409 S.C. 19
S.C.2014Background
- Inman was a juvenile when he committed robbery, kidnapping, and murder of Mary Alice Stutts and received life without parole.
- The State used peremptory challenges across multiple juries; Batson challenges were raised against several of Appellant’s strike decisions.
- Juror 60, a white farmer, was struck by defense, with the reason framed as his occupation and perceived education level.
- The circuit court granted the State’s Batson motion, barring defense challenges to three jurors, including Juror 60, leading to a final jury that seated Juror 60 as foreman.
- Appellant was convicted on all charges; on appeal, the Batson ruling was challenged as improper burden placement and pretext evaluation.
- The Supreme Court reversed, holding the Batson ruling erroneous and remanding for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Batson burden-shifting was properly applied | Inman contends the defense carried its burden at step two; the State bore burden at step three. | Inman argues the circuit court improperly placed the burden on the defense to prove pretext. | Yes; burden stayed with the State to prove pretext at step three. |
| Whether the unexplained reliance on race-neutral reasons was evaluated properly | Defense showed a facially race-neutral reason for striking Juror 60. | State claimed reasons were pretextual but failed to prove pretext at hearing. | Court held the reasons were not properly tested for pretext; error by circuit court. |
| Remedy for Batson error when a seated juror was struck | Batson error tainted the jury, warranting a new trial. | Not applicable or disputed post hoc justifications should not affect outcome. | New trial mandated; convictions reversed and remanded. |
Key Cases Cited
- Purkett v. Elem., 514 U.S. 765 (1995) (three-step Batson framework; race-neutral reasons at step two suffice to trigger step three)
- Snyder v. Louisiana, 552 U.S. 472 (2008) (pretext evaluation requires considering totality of evidence)
- Batson v. Kentucky, 476 U.S. 79 (1986) (prohibition on race-based peremptory strikes)
- State v. Ford, 334 S.C. 59 (1999) (employment as race-neutral reason; burden-shifting guidance in Batson hearing)
- State v. Evins, 373 S.C. 404 (2007) (burden of persuasion and pretext considerations in Batson)
- State v. Giles, 407 S.C. 14 (2014) (discusses step-two sufficiency and step-three pretext assessment)
- Edwards v. Haigler, 384 S.C. 504 (2009) (deference to trial court findings on discriminatory purpose)
- Oglesby v. State, 298 S.C. 279 (1989) (direct and circumstantial evidence considerations in Batson)