Ex Parte Christopher Anthony Floyd. (in Re Christopher Anthony Floyd v. State of Alabama)

Summary

The court reversed the Court of Criminal Appeals’ judgment because the trial court failed to make specific findings on whether the State’s peremptory strikes were race- and gender-neutral and whether purposeful discrimination occurred. The appellate court improperly performed the trial court’s fact-finding role by evaluating reasons for two strikes that the trial court had not addressed. Justice Murdock, concurring in the result, questioned whether a Batson inquiry may be initiated for the first time on appeal under plain-error review and emphasized that credibility determinations belong to the trial court.