Batson v. Kentucky
Batson v. Kentucky is a landmark Supreme Court case centered on the issue of racial discrimination in jury selection. In this case, James Batson, an African American man accused of burglary, faced an all-white jury after the prosecutor used peremptory challenges to exclude all African American jurors. Batson’s legal team argued that this exclusion violated his rights to equal protection and a jury representative of the community. The Supreme Court, by a 7-2 majority, ruled in favor of Batson, establishing that a pattern of racial exclusion creates an inference of discrimination that the prosecutor must justify with a neutral explanation. This ruling initiated a shift towards more equitable jury selection practices, requiring courts to scrutinize race-based exclusions during the voir dire process. The principles established in Batson have since been expanded, addressing not only racial discrimination but also gender discrimination in jury selection. Overall, Batson v. Kentucky has had a profound influence on ensuring fair representation in juries and protecting the constitutional rights of defendants.
Batson v. Kentucky
Date: April 30, 1986
Citation: 476 U.S. 79
Issue: Jury composition
Significance: The Supreme Court ruled that the equal protection clause of the Fourteenth Amendment forbids a prosecutor from using peremptory challenges to remove potential jurors because of their race.
James Batson, an African American, was indicted for second-degree burglary. When the judge conducted a voir dire examination (preliminary check of suitability and qualifications) of the potential jurors, the prosecutor used his peremptory challenges to remove all four African Americans from the panel, resulting in an all-white jury. The Supreme Court had refused to disturb the same development in Swain v. Alabama (1965). After Batson’s conviction, nevertheless, his lawyers asserted that the process of jury selection violated his rights to equal protection and to a jury drawn from a cross section of the community.
By a 7-2 majority, the Court accepted Batson’s claim. Speaking for the majority, Justice Lewis F. Powell, Jr., remanded the case and instructed the trial court to require the prosecutor to justify the exclusion of members of the defendant’s race from the jury. If the prosecutor were unable to give a racially neutral explanation, Batson’s conviction would have to be reversed. Powell’s opinion formulated a framework for future voir dire proceedings. The basic idea is that a pattern of exclusion based on race creates an inference of discrimination. Once such an inference is established, the prosecutor has the burden of showing that the peremptories are not discriminatory. Emphasizing that the Constitution does not guarantee a right to peremptory challenges, Powell wrote that potential jurors may not be eliminated simply because of the assumption that people of a particular race might be more sympathetic to a particular defendant. Thus, Powell’s opinion requires color-conscious rather than color-blind procedures in jury selection, and it tends to encourage the use of racial quotas.
The Batson principles have been significantly expanded. In Powers v. Ohio (1991), the Court held that criminal defendants may object to race-based peremptory challenges even if the defendant and the excluded jurors do not belong to the same race. Later that year, in Edmondson v. Leesville Concrete Co., the Court applied the Batson framework to the selection of juries in civil trials. In Georgia v. McCollum (1992), the Court decided that the Batson ruling applies to defense attorneys. In J. E. B. v. Alabama (1994), moreover, the Court held that the equal protection clause prohibits discrimination in jury selection on the basis of gender.