State v. Raynor, 334 Conn. 264

James Raynor, an African‑American, was convicted by a jury of first‑degree assault as an accessory and conspiracy to commit first‑degree assault; he appealed claiming a Batson violation during jury selection.
During voir dire the prosecutor used a peremptory challenge to excuse prospective juror R.E., citing his employment history and perceived security concerns; the trial court excused R.E. and noted (sua sponte) that R.E. was not the same race as the defendant.
Raynor argued the strike was racially motivated and pointed to two other venirepersons (I.L. and G.H.) whom the prosecutor accepted despite allegedly similar part‑time work restrictions.
The Appellate Court affirmed, holding the record inadequate to review Raynor’s unpreserved comparative Batson claim because the transcript did not show the races of R.E., I.L., or G.H., nor the racial composition of the empaneled jury.
The Connecticut Supreme Court granted certification, adopted the Appellate Court’s opinion, and affirmed: it agreed the record was inadequate and—alternatively—held the trial court’s finding of no purposeful discrimination was not clearly erroneous.
The Supreme Court declined to require mandatory pre‑selection racial identification of jurors, noting statutory and policy issues and referring broader reforms to a newly appointed Jury Selection Task Force.

Issue	Raynor's Argument	State's Argument	Held
Whether the record was adequate to review Raynor’s comparative Batson claim (challenge to peremptory strike of R.E. vs. acceptance of I.L. and G.H.)	The transcript permits comparative analysis showing disparate treatment; Appellate Court was wrong to deem the record inadequate	The record lacks necessary facts (races of R.E., I.L., G.H. and empaneled jury composition) so the Batson comparative claim is unreviewable	Appellate Court correctly concluded the record was inadequate; Supreme Court adopts that opinion and affirms
Whether the trial court’s Batson ruling (no purposeful discrimination in striking R.E.) was clearly erroneous	The prosecutor’s race‑neutral reason was pretextual given acceptance of similarly situated jurors	Trial court’s credibility determination was permissible; no clear error	Alternatively affirmed: trial court’s finding not clearly erroneous
Whether the Court should order jurors to identify race before selection (supervisory relief)	Mandatory racial identification would improve record and Batson adjudication	Mandatory disclosure raises statutory, administrative, privacy, and categorization issues; legislature and policy considerations implicated	Court declined to mandate identification; referred policy to Jury Selection Task Force

Batson v. Kentucky, 476 U.S. 79 (prohibits race‑based peremptory strikes)
Powers v. Ohio, 499 U.S. 400 (Batson standing extends beyond defendant’s own race)
State v. Golding, 213 Conn. 233 (standards for unpreserved claims review)
State v. Hodge, 248 Conn. 207 (racial composition of empaneled jury is a relevant, nondispositive Batson factor)
State v. Edwards, 314 Conn. 465 (Batson analysis and comparative inquiry considerations)
State v. Raynor, 175 Conn. App. 409 (Appellate Court opinion adopted by the Supreme Court)