The People v. Cory D. Williams
Categories
Attorneys and Parties
Brief Summary
Criminal law; jury selection and whether the prosecution improperly used peremptory challenges to strike Hispanic prospective jurors in violation of Batson v. Kentucky.
The County Court denied the defendant's Batson challenge, ruled that he failed to make a prima facie showing of discrimination, and convicted him of criminal possession of a controlled substance in the third degree after a jury trial.
The Appellate Division reversed the judgment of conviction and remitted the matter for a new trial.
The defendant satisfied Batson step one by showing that the prosecution struck the only three Hispanic prospective jurors. Although the prosecution then gave race-neutral reasons, the trial court improperly denied the challenge at the prima facie stage and failed to proceed to step three, where the defendant had to be allowed to argue that those reasons were pretextual. The appellate court reached the unpreserved issue under CPL 470.15(6) [authorizing appellate review in the interest of justice].
Background
Williams was tried in Orange County on a charge of criminal possession of a controlled substance in the third degree. During voir dire, the prosecution used a peremptory challenge to remove one Hispanic prospective juror in the first round and then sought to strike two more Hispanic prospective jurors in the second round. The defense raised a Batson challenge to the strike of the third Hispanic prospective juror, arguing that the People had moved to strike the only three Hispanic prospective jurors and that the pattern supported an inference of racial discrimination.
Lower Court Decision
The County Court required the defense to provide an additional reason for claiming discriminatory intent. After the defense reiterated its position, the prosecution gave facially race-neutral explanations for each of the three strikes. The court nevertheless denied the Batson challenge on the ground that the defendant had not met his prima facie burden and did not permit the defense to argue that the stated reasons were pretextual. The jury later convicted the defendant, and the court imposed sentence.
Appellate Division Reversal
The Appellate Division held that the defendant had satisfied Batson step one because the circumstances of voir dire raised an inference of discrimination when the prosecution sought to strike the only three Hispanic prospective jurors. Once that showing was made, the burden shifted to the People to provide race-neutral reasons, and after those reasons were given, the court was required to proceed to step three and allow the defendant to attempt to show pretext. Because the County Court failed to follow that process, the conviction was reversed and the matter was remitted for a new trial.
Legal Significance
The decision reinforces that Batson's first step is not onerous and that a pattern of striking all available members of a protected group can be enough to raise an inference of discrimination. It also makes clear that once race-neutral reasons are offered, the trial court must complete the third step of the Batson analysis rather than deny the challenge based on a supposed failure to make a prima facie showing.
A trial court commits reversible error when it short-circuits the Batson framework. If the facts permit an inference of discriminatory jury strikes and the striking party offers race-neutral reasons, the opposing party must be allowed to argue pretext before the court rules.