Supreme Court of Colorado
The People of the State of Colorado, Petitioner v. Heather Beauvais, Respondent
April 24, 2017393 P.3d 509
Summary
The court reversed the court of appeals and upheld the trial court’s denial of Beauvais’s gender-based jury-selection objections. It held that a Batson ruling need not include express credibility findings if the record shows that the trial court considered the relevant circumstances and supports its ultimate finding, and that comparative juror analysis is permissible on appeal only when the record permits a meaningful comparison of jurors on all material characteristics underlying the strikes. Justice Márquez, dissenting, would have remanded for factual findings because she believed the trial court’s conclusory ruling did not permit meaningful appellate review.