State v. Wilson

Summary

The Court held that the first step of the Batson inquiry was not moot because the trial court expressly ruled that defendant had failed to establish a prima facie case and never proceeded to determine whether the State's reasons were pretextual. The Court emphasized that step-one mootness is an exception requiring both the State's race-neutral explanations and the trial court's consideration and resolution of purposeful discrimination. It reversed the Court of Appeals and remanded for that court to review whether the trial court clearly erred at step one.