JACQUELINE SAMPSON, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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The appellant, a black woman defendant, objected to the State's use of peremptory challenges to exclude two black women from the jury panel, alleging systematic racial exclusion. The trial court denied the objection without conducting an inquiry into the State's rationale, and the appellate court reversed, holding that the trial judge was required to examine the State's racially neutral justification for the challenges.
The trial court erred by failing to conduct an inquiry into the State's basis for the peremptory challenge of Ms. Francis. Once the appellant made a timely objection and demonstrated that challenged persons were members of a distinct racial group with a strong likelihood they were challenged solely because of race, the State was required to provide a 'clear and reasonably specific' racially neutral explanation for its peremptory challenge, which it never did.
[1] A party objecting to the State's exercise of peremptory challenges must make a timely objection demonstrating that the challenged jurors are members of a distinct racial…
[2] Any doubt as to whether a complaining party has met its initial burden of showing a constitutionally impermissible exercise of peremptory challenges should be resolved in…
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Join FLexlaw to unlock all legal intelligence“In determining whether peremptory challenges have been used to exclude persons from jury service due to constitutionally impermissible prejudice, the issue is not whether several jurors have been excused because of their race, but whether any juror has been so excused, independent of any other.”
Establishes the framework for analyzing peremptory challenge challenges—focus is on individual jurors, not patterns of exclusion
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Join FLexlaw to unlock all legal intelligenceDuring jury selection, Ms. Hopkins, a black woman with family members who had been arrested and imprisoned and who had been a crime victim, was excuse…
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GARRETT, Judge.
During voir dire, Ms. Hopkins, a black woman, was called as a prospective juror. Upon questioning, she related that members of her family had been arrested, one had served a prison term, and one had been the victim of several crimes. The State exercised its first peremptory challenge in excusing her. Thereafter, Ms. Francis, a black woman, was called as a prospective juror. Upon questioning, she related that she was single, employed as a customer service representative, had never served as a juror, had never been involved in a lawsuit, and had never been the victim of a crime. The state exercised its second peremptory challenge in excusing her. Thereupon, through counsel, the appellant, a black woman, objected:
Judge, I think there is evidence of systematic exclusion and the State exercised only two strikes against two of the very few minorities on the panel being the same minority as my client and I object and move to strike the panel.
The Court: At this point the objection is denied. Any strikes by the Defense?
In determining whether peremptory challenges have been used to exclude persons from jury service due to constitutionally impermissible prejudice, the issue is not whether several jurors have been excused because of their race, but whether any juror has been so excused, independent of any other. State v. Slappy, 522 So. 2d 18 (Fla.), cert. denied, — U.S. -, 108 S.Ct. 2873, 101 L.Ed.2d 909 (1988).
The appellant made a timely objection and demonstrated on the record that the challenged persons were members of a distinct racial group and that there was a strong likelihood that they have been challenged solely because of their race. See State v. Neil, 457 So. 2d 481 (Fla.1984), clarified sub nom. State v. Castillo, 486 So. 2d 565 (Fla.1986). Any doubt as to whether the complaining party has met its initial burden of showing a constitutionally impermissible exercise of peremptory challenges should be resolved in the complaining party’s favor. Slappy, 522 So. 2d at 22.
The trial judge should have been satisfied that the appellant’s objection as to the peremptory challenge of Ms. Francis was proper and not frivolous. He should have conducted an inquiry into the state’s basis for excusing her. The state should have been required to rebut the inference created when the appellant met his initial burden of persuasion. The rebuttal must consist of a “clear and reasonably specific” racially neutral explanation of “legitimate reasons” for the state’s use of its peremptory challenge. Id.
No inquiry was conducted, therefore, the state never met its burden of rebutting the inference that Ms. Francis was peremptorily challenged for constitutionally impermissible reasons. We reverse and remand for a new trial.
REVERSED AND REMANDED.
ANSTEAD and LETTS, JJ., concur.
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Hill v. State, 547 So. 2d 175 (Fla. 4th DCA 1989)…demonstrating on the record that the challenged person was a member of a distinct racial group and that there was a strong likelihood that she was challenged solely because of her race. See State v. Neil, 457 So. 2d 481 (Fla.1984); Sampson v. State, 542 So. 2d 434 (Fla. 4th DCA 1989). Furthermore, any doubt as to whether the defendant satisfied his burden of showing that the juror was challenged solely because of her race should be resolved in his favor. See State v. Slappy, 522 So. 2d 18, 22 (Fla.), cert. de…
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Green v. State, 572 So. 2d 543 (Fla. 2d DCA 1990)…e sole prospective black juror on the venire after another black juror had been excused for cause); Mack v. State, 545 So. 2d 489 (Fla.2d DCA 1989) (state had peremptorily challenged three out of five black prospective jurors); and Sampson v. State, 542 So. 2d 434, 435 (Fla. 4th DCA 1989) (state used its first two peremptory challenges against two of the “very few minorities on the panel”). The potential range of other circumstances under which that initial burden could be carried has not been spelled out in…
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Gonzalez v. State, 569 So. 2d 782 (Fla. 4th DCA 1990)…rt recognized that the appellee could offer a racially neutral explanation, supported by the record, for the challenge. The involvement of a juror’s close family member with the law is a valid reason for a peremptory challenge. Cf. Sampson v. State, 542 So. 2d 434 (Fla. 4th DCA 1989). See also United States v. Vaccaro, 816 F. 2d 443 (9th Cir.1987), cert. denied, 484 U.S. 928, 108 S.Ct. 295, 98 L.Ed.2d 255 (1987). The state is not required to provide any additional explanation. See Reed v. State, 560 So. 2d 20…
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Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- State v. Neil, 457 So. 2d 481 (Fla. 1984)
- State v. Slappy, 522 So. 2d 18 (Fla. 1988)
- State v. Castillo, 486 So. 2d 565 (Fla. 1986)