Sells v. State

Summary

The Delaware Supreme Court reversed Sells’s convictions and remanded for a new trial because the Superior Court improperly found a prima facie reverse-Batson violation based on Sells’s strikes of two white jurors and improperly required him to provide a race-neutral explanation. The court held that the State had not shown sufficient facts to support an inference of purposeful racial discrimination and that the separately exercised strikes of Sells and his codefendant could not be aggregated. Because Juror #8 was seated after Sells’s valid peremptory challenge was denied, prejudice was presumed. The court did not reach Sells’s severance claim.