State v. Holmes

Summary

The court affirmed the denial of the defendant’s Batson challenge to the prosecutor’s peremptory strike of an African-American prospective juror who had expressed distrust of law enforcement and concerns about the fairness of the criminal justice system. It held that those reasons were facially race neutral under federal equal protection law even if they may disproportionately affect minority jurors, and the defendant did not adequately challenge the finding that the reasons were not pretextual. The court nevertheless referred broader concerns about implicit bias and disparate impact in jury selection to a Jury Selection Task Force.