Batson v. Kentucky (1986)
Batson v. Kentucky (1986): No Racial Discrimination in Jury Selection
Striking jurors because of race violates the Equal Protection Clause.
Background
James Batson, a Black defendant, was tried in Kentucky. Prosecutors used peremptory strikes to remove all Black jurors, resulting in an all-white jury. Batson argued this violated his constitutional rights. Historically, peremptory challenges were unchecked, allowing discrimination to influence jury composition.
Questions Presented
- Does purposeful racial discrimination through jury strikes violate the Equal Protection Clause?
- What procedure governs objections to discriminatory strikes?
Majority Opinion — Justice Lewis F. Powell, Jr.
Holding: Prosecutors cannot use peremptory strikes to exclude jurors solely because of race. A three-step review applies when discrimination is alleged.
Powell’s opinion established a framework:
- The defense must show facts giving rise to an inference of discriminatory strikes.
- The prosecution must articulate a race-neutral explanation.
- The judge decides if purposeful discrimination occurred.
The ruling protects the integrity of the jury system by ensuring jurors are chosen based on qualifications — not stereotypes. The decision applies to defense strikes as well, and later cases extended it to gender and other classifications.
In Montgomery County courts, Batson challenges occur during jury selection when the State disproportionately strikes jurors of a particular race. Defense counsel must be ready to identify patterns quickly — and preserve the issue for appeal.
Racial bias in jury selection undermines confidence in verdicts. Batson prevents trial outcomes from being tainted by prejudice rather than evidence.