Williams v. State, 429 P.3d 301

Gregory Williams was convicted of six sexual-offense counts involving two girls (ages 10 and 12); physical and DNA evidence tied him to at least one victim.
During jury selection the State used a peremptory strike to remove Juror 23, an African‑American woman; Williams raised a Batson challenge.
The district court accepted the State's race-neutral reasons and denied Batson after minimal analysis and before giving Williams an opportunity to rebut pretextuality.
Williams also sought to introduce evidence that the victims had sexual knowledge (mother worked in porn/sex-related business) to support a defense that the girls could fabricate allegations; the district court denied the request without a full Summitt hearing and required the State to "open the door."
The Nevada Supreme Court found the Batson analysis deficient (court failed to conduct step three; State offered a partly pretextual explanation) and held the Batson denial was clear error requiring reversal and remand for a new trial.
The Court also directed the trial court on the proper Summitt procedure for admitting evidence of a young victim's sexual knowledge and explained the required pretrial offer-of-proof and in‑camera hearing balancing probative value against prejudice.

Issue	Plaintiff's Argument (Williams)	Defendant's Argument (State)	Held
Whether the State's peremptory strike of Juror 23 violated Batson	Strike was race‑based; record shows similar non‑black jurors gave like answers and were not struck, so prima facie discrimination and pretext	Strike was race‑neutral: juror expressed skepticism of science and displayed a "closed‑off" demeanor making her unfit to deliberate	Reversed: district court failed to perform step‑three inquiry; State's non‑demeanor reason appears pretextual; Batson denial was clear error and requires retrial
Whether evidence of the victims' exposure to sexual information (mother's porn/sex‑work) is admissible to show ability to fabricate allegations (Summitt)	Evidence is relevant to show the girls had knowledge to contrive specific sexual details; Summitt allows such evidence and a hearing outside jury	Rape‑shield bars past sexual‑conduct evidence; probative value is low and evidence would be unduly prejudicial unless State "opens the door"	Reversed in part: district court erred by categorically excluding evidence and by not holding the Summitt/Guitron hearing; established procedure and balancing test required on remand

Batson v. Kentucky, 476 U.S. 79 (prohibits race‑based peremptory strikes; three‑step Batson framework)
Snyder v. Louisiana, 552 U.S. 472 (trial record must show whether demeanor or other reasons credited; summary rulings may be insufficient)
Miller‑El v. Dretke, 545 U.S. 231 (comparative juror analysis: if prosecutor's reason fits non‑black jurors who sat, that supports pretext)
Purkett v. Elem, 514 U.S. 765 (prosecutor needs only an ostensibly race‑neutral explanation at step two)
Hernandez v. New York, 500 U.S. 352 (procedural aspects of Batson steps and deference to trial judge's demeanor findings)
Summitt v. State, 101 Nev. 159 (697 P.2d 1374) (rape‑shield construed to permit evidence showing a young victim's knowledge to fabricate allegations)
Diomampo v. State, 124 Nev. 414 (185 P.3d 1031) (discusses Batson structural error and comparative juror analysis)