State of Louisiana v. Larry Broussard, Jr. AKA Larry James Broussard, Jr. AKA Larry J. Broussard, Jr.

Summary

The court affirmed the court of appeal’s decision vacating the defendant’s conviction and sentence because the trial court improperly denied a Batson challenge without making clear whether it credited the prosecutor’s demeanor-based reason for striking an African-American prospective juror. Once the prosecutor offered race-neutral reasons and the trial court ruled on the challenge, the reviewing court could not truncate the inquiry by revisiting whether the defendant established a prima facie case. The reviewing court also could not presume from the trial court’s silence that it accepted the demeanor-based reason after rejecting the prosecutor’s other reason.