## Facts

- James Kirkland Batson, a Black defendant, was tried in Kentucky state court for second-degree burglary and receipt of stolen goods.
- During voir dire, the prosecutor used peremptory challenges to strike all four Black prospective jurors, resulting in an all-white jury.
- Batson moved to discharge the jury, arguing that the strikes violated the Sixth Amendment fair-cross-section requirement and the Fourteenth Amendment Equal Protection Clause.
- The trial court denied the motion without an evidentiary hearing, and Batson was convicted.
- The Kentucky Supreme Court affirmed, applying *Swain v. Alabama* and requiring proof of long-term “systematic” exclusion.
- The U.S. Supreme Court granted review.

## Issues

1. Whether the Equal Protection Clause forbids a prosecutor from using peremptory challenges to strike prospective jurors solely because of their race in a particular case.
2. Whether an equal-protection claim based on peremptory strikes requires proof of long-term “systematic” exclusion, as described in *Swain v. Alabama*.

## Decision

- The Court reversed the state-court judgment (7–2).
- The Equal Protection Clause forbids prosecutors from striking prospective jurors solely on account of race or on the assumption that jurors of a race, as a group, cannot be impartial.
- The Court rejected *Swain*’s evidentiary requirement to the extent it demanded proof of discrimination “in case after case” as a prerequisite to relief.
- The Court adopted a burden-shifting framework permitting a defendant to prove purposeful discrimination using evidence from the prosecutor’s strikes at the defendant’s own trial.

## Legal Principles

- A State violates equal protection when it purposefully excludes jurors on the basis of race.
- A defendant is not entitled to a petit jury containing jurors of the defendant’s race, but is entitled to jury-selection procedures free of racial exclusion.
- Equal-protection limits applicable to selection of the venire also constrain the prosecutor’s use of peremptory challenges.
- Three-step framework for evaluating race-discrimination claims in peremptory strikes:
  - The defendant must make a prima facie showing that relevant facts and circumstances raise an inference that the prosecutor struck jurors because of race.
  - If shown, the burden shifts to the prosecutor to offer a race-neutral explanation that is clear, reasonably specific, and related to the case.
  - The trial court must decide whether the defendant has proved purposeful discrimination.
- Racial discrimination in jury selection harms the defendant, excluded jurors, and public confidence in the fairness of the justice system.

## Conclusion

The Court held that race-based peremptory strikes violate the Equal Protection Clause and allowed defendants to establish purposeful discrimination based on the prosecutor’s conduct in the defendant’s own case through a burden-shifting test requiring race-neutral explanations and trial-court findings.


Batson v. Kentucky, 476 U.S. 79 (1986)