306 P.3d 942
Wash.2013Background
- The Equal Protection Clause prohibits racial discrimination in jury selection per Batson.
- The Batson three-part test includes a prima facie showing of discrimination at step one.
- State v. Rhone (2010) wrestled with whether Rhone created a bright-line rule for prima facie cases.
- Meredith was charged in 1996 with rape of a child and related offenses; juror 4 was the sole African-American on the venire struck peremptorily.
- Meredith objected under Batson; trial court denied relief; convictions followed.
- Meredith absconded before sentencing; years later the case revisited Rhone's scope.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Scope of Rhone's bright-line rule | Meredith seeks application of Rhone's bright-line rule to his case. | State argues Rhone did not establish a bright-line rule; pre-Rhone framework applies. | Rhone did not establish a bright-line rule. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (U.S. Supreme Court, 1986) (three-part Batson test for discrimination in jury selection)
- State v. Rhone, 168 Wn.2d 645 (Wash. 2010) (discussed scope of prima facie Batson analysis and rule clarity)
- State v. Hicks, 163 Wn.2d 477 (Wash. 2008) (pre-Rhone Batson framework guidance)
- State v. Thomas, 166 Wn.2d 380 (Wash. 2009) (pre-Rhone Batson framework guidance)
- Johnson v. California, 545 U.S. 162 (U.S. Supreme Court, 2005) (state flexibility in formulating Batson prima facie approaches)
- State v. Saintcalle, 178 Wn.2d 34 (Wash. 2013) (Batson's effectiveness and scope discussed; critique of peremptory challenges)