DANIEL L. CZAJA, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Daniel Czaja appeals his conviction for DUI manslaughter arising from a fatal traffic accident. The appellate court reverses and remands because the trial court improperly sustained the prosecution's objection to a peremptory juror strike without conducting the required inquiry into whether the strike was motivated by racial discrimination.
The prosecution's objection was insufficient because it failed to refer to race or discrimination and did not meet the minimum threshold required to invoke a Neil inquiry. Even if the objection had been sufficient, the trial court erred in sustaining it because defense counsel provided a race-neutral reason for the strike (the juror's wife was a law enforcement officer), and the trial court failed to determine whether purposeful racial discrimination had been proven.
[1] A prosecutor's objection to a peremptory strike must specifically state that the strike is being used in a racially discriminatory manner to invoke a Neil inquiry.
[2] A close relationship between a prospective juror and a law enforcement officer constitutes a race-neutral reason for exercising a peremptory strike.
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Join FLexlaw to unlock all legal intelligence“a peremptory strike will be deemed valid unless an objection is made that the challenge is being used in a racially discriminatory manner.”
Establishes the standard that only objections based on racial discrimination can overcome the presumption of validity of peremptory strikes.
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Join FLexlaw to unlock all legal intelligenceCzaja was charged with DUI manslaughter and two counts of driving under the influence with serious bodily injury following a fatal traffic accident. D…
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PATTERSON, Judge.
Daniel Czaja appeals from his judgment and sentence that arose from a fatal traffic ' accident. Czaja was charged with one count of DUI manslaughter and two counts of driving under the influence with serious bodily injury. His jury trial commenced on October 17, 1994. During the course of voir dire, Czaja attempted to make a peremptory strike of juror Monroe. The following exchange occurred:
[DEFENSE COUNSEL]: I would then strike Mr. Monroe, Judge.
[PROSECUTOR]: I would raise a Neal [sic] challenge at this time because this particular juror did not give any biased opinions.
THE COURT: Okay. What reason do you have? [DEFENSE COUNSEL]: Judge, his wife is a law enforcement officer. The trial court sustained the state’s objection to the peremptory strike. Czaja argues that the state’s objection was insufficient to invoke a Neil1 inquiry, and if it was sufficient, it was nonetheless error to sustain the objection. We agree and reverse.
In State v. Johans, 613 So. 2d 1319, 1322 (Fla.1993), our supreme court clarified what is necessary to invoke a Neil inquiry, saying:
Under our decision today, the presumption of validity of peremptory strikes established in Neil is still the law in Florida. Furthermore, a peremptory strike will be deemed valid unless an objection is made that the challenge is being used in a racially discriminatory manner. The state’s objection fails to refer to race or discrimination and does not meet the minimum threshold.
Even if the objection were sufficient to trigger a Neil inquiry, Czaja’s counsel gave a reasonable and specific reason to meet the requirements of Johans and Neil. A close relationship between the juror and a law enforcement officer is a race-neutral reason for exercising a peremptory strike. See Alexander v. State, 643 So. 2d 1151 (Fla. 3d DCA 1994). Once defense counsel has given a race-neutral reason for the strike, the trial court has the duty to determine “whether the opponent of the strike has proved purposeful racial discrimination.” Purkett v. Elem, — U.S. -, -, 115 S.Ct. 1769, 1771, 131 L.Ed.2d 834 (1995). Nothing in the transcript reveals that the trial court considered this issue. Therefore, we reverse and remand for a new trial.
Reversed and remanded.
CAMPBELL, A.C.J., and QUINCE, J., concur. . State v. Neil, 457 So. 2d 481 (Fla.1984), receded from in part by State v. Johans, 613 So. 2d 1319 (Fla.1993).
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Hayes v. State, 94 So. 3d 452 (Fla. 2012)…neutral or gender neutral reason for a peremptory strike”); Chambers v. State, 682 So. 2d 615, 615 (Fla. 4th DCA 1996) (“[T]he law enforcement background of a juror’s spouse is a properly neutral reason for a peremptory challenge-”); Czaja v. State, 674 So. 2d 176, 177 (Fla. 2d DCA 1996) (“A close relationship between the juror and a law enforcement officer is a race-neutral reason for exercising a peremptory strike.”). Since the reason defense counsel offered was facially gender neutral, the trial court was…
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Chambers v. State, 682 So. 2d 615 (Fla. 4th DCA 1996)…enial of his motion to peremptorily strike Lavalley constituted a reversible error. Florida law presumes that a peremptory challenge has been exercised without invidious discrimination. Windom v. State, 656 So. 2d 432 (Fla.1995). In Czaja v. State, 674 So. 2d 176 (Fla. 2d DCA 1996), the second district recognized that the law enforcement background of a juror’s spouse is a properly neutral reason for a peremptory challenge, invoking the trial court’s duty to determine whether the State’s objection to the str…
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Landis v. State, 143 So. 3d 974 (Fla. 4th DCA 2014)…al or gender neutral reason for a peremptory strike"); Chambers v. State, 682 So. 2d 615, 615 (Fla. 4th DCA 1996) (”[T]he law enforcement background of a juror's spouse is a properly neutral reason for a peremptory challenge .... ”); Czaja v. State, 674 So. 2d 176, 177 (Fla. 2d DCA 1996) ("A close relationship between the juror and a law enforcement officer is a race-neutral reason for exercising a peremptory strike.”); Rivera v. State, 670 So. 2d 1163, 1166-67 (Fla. 4th DCA 1996) (permissible to strike deput…
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Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- State v. Neil, 457 So. 2d 481 (Fla. 1984)
- Purkett v. Elem, 514 U.S. 765 (U.S. 1995)
- State v. Johans, 613 So. 2d 1319 (Fla. 1993)
- Alexander v. State, 643 So. 2d 1151 (Fla. 3d DCA 1994)