579 U.S. 911
SCOTUS2016Background
- Jabari Williams sought certiorari after Louisiana courts applied a state rule allowing trial judges to supply race-neutral reasons for peremptory strikes rather than requiring the prosecutor to explain the strike.
- The Supreme Court granted, vacated, and remanded the judgment for reconsideration in light of Foster v. Chatman.
- Justice Ginsburg (joined by Breyer, Sotomayor, Kagan) concurred, emphasizing Batson’s three-step framework and that at Batson’s second step the prosecutor must provide the race-neutral reason.
- Louisiana Code Crim. Proc. Ann. Art. 795(C) permits the court to provide a race-neutral reason if it is apparent from voir dire; Louisiana courts have recognized tension between that rule and Batson.
- On remand the state court was directed to reconsider whether the judge‑supplied‑reason rule can be reconciled with Batson and related precedent requiring the prosecutor to give answers.
- Justice Alito (joined by Thomas) dissented from the GVR, arguing Foster addressed only Batson’s third step and that the Ginsburg concurrence’s focus on step two was not implicated by Foster.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a trial judge may supply a race‑neutral reason for a prosecutor’s peremptory strike under Batson | Louisiana’s judge‑supplied reason rule violates Batson because the prosecutor must be required to provide the race‑neutral explanation | State argues the judge can identify an apparent race‑neutral reason based on voir dire under state procedure | Court GVRed and remanded for reconsideration in light of Foster; concurrence instructs state courts to revisit compatibility of judge‑supplied reasons with Batson’s requirement that prosecutors give explanations |
| Whether Foster v. Chatman controls resolution of Williams’s Batson claim | Williams: Foster’s principles about assessing discriminatory intent require scrutiny of the reason for strikes and adherence to Batson’s steps | State (per dissent): Foster addressed only Batson’s third step and does not control the step‑two judge‑reason question | Court vacated and remanded for reconsideration in light of Foster; dissent would have denied relief, viewing Foster as inapposite |
| Whether federal interpretation of Batson binds Louisiana courts in applying Art. 795(C) | Williams: federal Batson precedent binds state courts; judge cannot replace prosecutor at step two | State: invokes state procedural rule permitting judge explanation | Remand directs state court to apply Supreme Court Batson precedent rather than rely on judge‑supplied reasons |
| Whether judicial speculation may be used to resolve Batson claims | Williams: judicial speculation is improper; prosecution must provide real reasons | State: reliance on voir dire may justify judge’s conclusion | Concurrence reiterates Johnson v. California: courts should not rely on judicial speculation to resolve plausible discrimination claims; prosecutor must be asked to explain |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (establishing procedure for challenging race-based peremptory strikes)
- Johnson v. California, 545 U.S. 162 (trial court must demand explanation from prosecutor; judicial speculation insufficient)
- Foster v. Chatman, 578 U.S. _ (2016) (addressing discriminatory intent in peremptory strikes and Batson analysis)
- James v. Boise, 577 U.S. _ (2016) (state courts bound by this Court’s interpretation of federal law)