Stroia v. State, 119 So. 3d 1274

Defendant charged with armed trespass of a structure and improper exhibition of a firearm after entering the Broward County Courthouse with a firearm.
During voir dire, several prospective jurors disclosed family members with arrest histories: Jurors 2 (white) and 9 (white) had close relatives arrested for drug offenses; Juror 22 (Black) had two brothers and a sister arrested (one for drugs) but said he could be fair and impartial.
The State used a peremptory strike to remove juror 22; defense objected under Batson/Melbourne as racially motivated, noting the State accepted jurors 2 and 9 despite similar family-arrest facts.
The State offered a race-neutral reason: juror 22 had multiple family arrests and was "very quiet."
The trial court found the proffered reason facially race neutral and not pretextual (noting the State had accepted other Black jurors and had struck non-Black jurors) and sustained the strike; defendant was later convicted.
On appeal the Fourth DCA reviewed for clear error and concluded the trial court erred: juror 22 was similarly situated to accepted white jurors, so the proffered reason was not genuine; convictions reversed and new trial ordered.

Issue	Appellant's Argument	State's Argument	Held
Whether the State’s peremptory strike of an African‑American venireperson was racially discriminatory under Batson/Melbourne	The strike was pretextual because the stated reason (family arrests) equally applied to white jurors 2 and 9 whom the State accepted	The reason was race neutral: juror 22 had multiple family arrests and was very quiet; overall circumstances show non‑discriminatory use of peremptories (accepted other Black jurors; struck non‑Black jurors)	The court held the trial court clearly erred; the proffered reason was not genuine because similarly situated white jurors were accepted; reverse and remand for new trial

Melbourne v. State, 679 So.2d 759 (Fla. 1996) (establishes three‑step Batson procedure in Florida)
Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (prohibits race‑based peremptory challenges; sets burden‑shifting framework)
Nowell v. State, 998 So.2d 597 (Fla. 2008) (peremptory strike invalid where stated reason applied equally to similarly situated white juror)
Foster v. State, 732 So.2d 22 (Fla. 4th DCA 1999) (reversing strike where reason—family arrests—was equally applicable to non‑black jurors not struck)
Wallace v. State, 889 So.2d 928 (Fla. 4th DCA 2004) (holding seating of some minority jurors does not cure discriminatory strikes)
Abshire v. State, 642 So.2d 542 (Fla. 1994) (minority jurors seated does not make a discriminatory strike harmless)
Hayes v. State, 94 So.3d 452 (Fla. 2012) (trial court must assess genuineness of proffered reasons and judge credibility under Melbourne)