People v. Jones, 2 N.Y.3d 235 (2004)

A defendant raising a Batson challenge must present more than “sketchy assertions” that a peremptory strike was racially motivated; a showing that the juror gave neutral answers is insufficient to establish a prima facie case of discrimination.

Summary

Defendant Lionel Jones appealed his conviction, arguing that the prosecutor’s use of a peremptory challenge against a Black prospective juror violated Batson v. Kentucky. The New York Court of Appeals affirmed the lower court’s decision, holding that Jones failed to establish a prima facie case of discrimination. The Court found that Jones’s assertions that the juror’s answers were neutral and gave no reason to believe she couldn’t be impartial were insufficient to meet his burden. The court also determined that the police had founded suspicion to justify a common-law inquiry.

Facts

During jury selection, the prosecutor used a peremptory challenge to strike an African-American prospective juror. Defense counsel raised a Batson challenge, arguing that the strike was racially motivated. Defense counsel contended that the juror’s responses were neutral and provided no basis to believe she could not be impartial. The trial court rejected the Batson challenge. The defendant was convicted.

Procedural History

The trial court convicted the defendant. The Appellate Division affirmed the conviction. The New York Court of Appeals granted leave to appeal. The Court of Appeals affirmed the Appellate Division’s order.

Issue(s)

1. Whether the defendant met his burden of establishing a prima facie case of discrimination under Batson v. Kentucky based on the prosecutor’s use of a peremptory challenge against an African-American prospective juror.
2. Whether the police possessed founded suspicion of criminality justifying a common-law inquiry.

Holding

1. No, because the defendant’s “sketchy assertions” and the fact that the prospective juror “indicated no reason why [the juror] could not serve fairly” are insufficient to establish a prima facie case of discrimination.
2. Yes, because the hearing court’s determination is supported by the record.

Court’s Reasoning

The Court of Appeals relied on its prior holdings in People v. Smocum and People v. Childress to determine whether the defendant had met the initial burden of establishing a prima facie case of discrimination. The court emphasized that a party raising a Batson challenge need not establish a pattern of discrimination but must provide more than “sketchy assertions” to suggest discriminatory intent. The Court stated that declarations that the prospective juror “indicated no reason why [the juror] could not serve fairly” are insufficient to establish a prima facie case of discrimination. Citing People v. Childress, the Court found that defense counsel’s contentions that the prosecutor’s peremptory challenge of an African-American prospective juror must have been based on her race because the challenged juror’s answers were “neutral” and “would not give [the prosecutor] any reason to believe that she could [not] be impartial” were “exactly the kind of vague and conclusory assertions” that the court had previously rejected.