199 So. 3d 1222
La. Ct. App.2016Background
- Defendant Jabari Williams, an African-American, was convicted of second-degree murder and sentenced to life without parole after confessing to a shooting; he claimed self-defense.
- During jury selection the State used 11 of 12 peremptory strikes to remove African-American venirepersons across two panels; the trial judge required race-neutral reasons for some strikes but refused to force the prosecutor to explain three challenged strikes.
- Williams raised Batson objections challenging the pattern of strikes; the trial court found no prima facie case as to the three jurors for which the prosecutor did not provide reasons and denied relief.
- On direct appeal the Fourth Circuit affirmed; the U.S. Supreme Court granted certiorari, vacated, and remanded in light of Foster v. Chatman (a Batson reversal) for reconsideration.
- On remand the Fourth Circuit reconsidered whether Williams made a Batson step-one prima facie showing that the three challenged strikes were race-based and reinstated the conviction and sentence.
Issues
| Issue | Williams' Argument | State's Argument | Held |
|---|---|---|---|
| Whether Williams made a Batson step-one prima facie showing as to the three jurors for whom the prosecutor did not supply race-neutral reasons | The pattern (11 of 11/12 strikes against Black venirepersons) and courtroom context raise an inference of racial discrimination requiring the State to articulate race-neutral reasons | The trial court never advanced beyond step one; Williams failed to produce contextual evidence beyond raw numbers, so burden never shifted to State | No prima facie showing as to the three jurors; conviction and sentence reinstated |
| Whether Foster (a step-three Batson decision) requires relief here | Foster shows courts must scrutinize patterns and credibility of proffered reasons; remand warranted to reconsider Batson claim | Foster addressed step three and fact-specific record; it did not change Batson’s three-step framework or mandate relief here | Foster did not alter the governing Batson standards applicable to this step-one inquiry; not controlling to require reversal here |
| Whether Louisiana’s practice (La. C.Cr.P. art. 795(C)) permitting judge-supplied race-neutral reasons conflicts with Batson | Williams (and the concurrence in the Supreme Court’s GVR) argued judge-supplied reasons violate Batson and the State must provide reasons | State and majority note Elie allowed judge-supplied reasons when apparent from voir dire; here the court never reached step two, so Elie is inapposite | The court did not decide the statewide rule’s validity; because the trial court did not find a prima facie case it never reached step two, so no Batson step-two error was found |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (prohibits race-based peremptory strikes)
- Foster v. Chatman, 578 U.S. (reversed conviction for Batson violation based on case-specific record showing race-conscious jury selection)
- Miller-El v. Dretke, 545 U.S. 231 (statistical, comparative, and voir dire question contrasts relevant to Batson analysis)
- Johnson v. California, 545 U.S. 162 (describes prima facie burden at Batson step one)
- Hernandez v. New York, 500 U.S. 352 (once prosecutor offers race-neutral reasons and court rules, the prima facie issue becomes moot)
- Snyder v. Louisiana, 552 U.S. 472 (reiterates Batson three-step framework and judicial role in assessing credibility of proffered reasons)