The People of the State of Colorado, Petitioner v. Heather Beauvais, Respondent

Summary

The court held that a trial court need not make express credibility findings for every prosecution explanation in a Batson challenge if the record shows that it considered the relevant circumstances and supports its ultimate finding that purposeful discrimination was not proved. It also held that appellate comparative-juror analysis is permissible even when not raised below, but only when the record permits a meaningful comparison of jurors with respect to all characteristics underlying the strike. Applying those rules, the court found no clear error in denying Beauvais’s Batson objections and reversed the court of appeals. Justice Márquez, dissenting, would have remanded for factual findings because she concluded the trial record did not support meaningful appellate deference.