Background - Defendant John C. Douglas (African American) was charged with two counts of first‑degree murder and one count of attempted first‑degree murder after shooting three people; tried jointly with a co‑defendant. - While jailed pretrial at Ada County Jail, Douglas complained his rotating one‑hour daily free time limited his ability to communicate with out‑of‑state (pro hac vice) and Idaho counsel and moved to compel broader access; the district court denied the motion. - During jury selection the State used a peremptory strike on the only African‑American venireperson after she stated law enforcement is "unfair to black people" and that she could not focus on Fridays; the district court denied Douglas’s Batson challenge. - At trial a detective made a nonresponsive statement describing information from a confidential informant; the court struck the statement as hearsay, instructed the jury to disregard it, but denied a mistrial motion. - Jury convicted Douglas on all counts; district court sentenced him to two fixed life terms and a concurrent 15‑year determinate term. Douglas appealed, arguing (1) Batson error, (2) ineffective assistance/denial of access to counsel, and (3) mistrial error from the hearsay statement. The Court of Appeals affirmed. ### Issues | Issue | Plaintiff's Argument (State) | Defendant's Argument (Douglas) | Held | |---|---:|---|---:| | Validity of Batson challenge to State's peremptory strike | Strike was race‑neutral: juror biased against law enforcement and unable to focus on key trial day | Strike was racially motivated because juror was the only African‑American in the pool and Douglas is African‑American | Court: Denial of Batson challenge affirmed — State gave race‑neutral reasons; defendant waived further pretext argument by accepting State's explanations and record showed no clear error | | Right to effective assistance / access to counsel while jailed | Jail provided opportunity to call counsel during daily free time; record shows numerous calls were placed and some answered | One‑hour rotating free time was insufficient to consult with Pennsylvania and Idaho counsel effectively, depriving Sixth Amendment right | Court: No deprivation — Douglas failed to show unconstitutional denial; call logs showed meaningful access, so motion to compel was properly denied | | Denial of mistrial after hearsay CI statement by a detective | Statement was nonresponsive and struck; curative instruction sufficed; no overwhelming probability jury couldn't follow instruction | Statement was extraordinarily prejudicial and likely used by jury to convict; mistrial required | Court: Denial of mistrial affirmed — struck testimony and jury instruction cured error; no showing jury could not follow instruction or that effect was devastating | | Standard of review for prejudice from trial events | (State) Appellate review asks whether the triggering event was reversible error in context of full record | (Douglas) Urges a finding of reversible error based on prejudicial effect | Court: Applied reversible‑error/harmlessness framework; upheld district court findings as not clearly erroneous | ### Key Cases Cited Batson v. Kentucky, 476 U.S. 79 (1986) (prohibits race‑based peremptory challenges and establishes three‑step test) Purkett v. Elem, 514 U.S. 765 (1995) (explains race‑neutral explanation standard and that offered reasons need not be persuasive) Strickland v. Washington, 466 U.S. 668 (1984) (framework for effective assistance of counsel) Neder v. United States, 527 U.S. 1 (1999) (harmless‑error analysis for constitutional errors) State v. Foster, 152 Idaho 88, 266 P.3d 1193 (Ct. App. 2011) (Idaho application of Batson framework) State v. Perry, 150 Idaho 209, 245 P.3d 961 (discusses structural errors and burden on State when a constitutional violation is shown) * State v. Ruiz, 159 Idaho 722, 366 P.3d 644 (Ct. App. 2015) (presumption that jury follows curative instruction unless overwhelming probability otherwise)