Byrd v. State

Summary

The Supreme Court of Georgia affirmed Byrd’s convictions, holding that the trial court properly applied the three-step framework governing a criminal defendant’s allegedly racially discriminatory peremptory strikes. Although the trial court did not expressly identify each step, the record showed that it allowed race-neutral explanations, heard the State’s responses, evaluated potential pretext and discriminatory intent, and reseated three jurors. No separate opinions were filed.