## Facts

- Allen Snyder, a Black defendant, was tried in Louisiana for first-degree murder; the State sought the death penalty.
- During voir dire, the prosecutor used peremptory challenges to remove all five Black venire members who remained after challenges for cause, resulting in an all-white jury.
- The defense raised objections under Batson v. Kentucky, including to the peremptory strike of Jeffrey Brooks, a Black college senior completing a student-teaching assignment.
- The prosecutor offered two reasons for striking Brooks: (1) Brooks appeared “nervous,” and (2) Brooks’s student-teaching obligations might lead him to favor a quick verdict to avoid missing school.
- Brooks expressed concern about missing student teaching, but a court staff member reported that Brooks’s dean would work with him if he missed time for trial that week; the prosecutor did not further probe the issue.
- The trial court overruled the Batson objections and allowed the strike without giving an explanation.
- The jury convicted Snyder and sentenced him to death.

## Issues

1. Whether the trial court committed clear error under Batson in accepting the State’s race-neutral explanations for striking Jeffrey Brooks.
2. Whether comparative treatment of similarly situated white jurors showed that the stated reasons were pretextual, establishing purposeful discrimination in violation of the Equal Protection Clause.

## Decision

- The Supreme Court reversed the Louisiana Supreme Court and remanded.
- The Court held that the trial court committed clear error in overruling Snyder’s Batson objection to the peremptory strike of Jeffrey Brooks.
- The Court declined to sustain the strike based on “nervousness” because the record did not show that the trial judge actually credited the demeanor-based explanation.
- The Court found the student-teaching rationale insufficient and indicative of pretext when compared with the State’s acceptance of white jurors who expressed equal or greater scheduling conflicts.
- Justice Thomas, joined by Justice Scalia, dissented, arguing for greater deference to the trial court’s evaluation of the prosecutor’s motives.

## Legal Principles

- Batson employs a three-step framework: (1) the defendant must make a prima facie showing of racial discrimination, (2) the prosecutor must provide race-neutral reasons, and (3) the court must decide whether the defendant proved purposeful discrimination.
- Appellate courts generally defer to trial-court Batson findings but may reverse when the ruling is clearly erroneous.
- Demeanor-based justifications require a record showing that the trial judge actually credited the asserted demeanor observation.
- Comparative juror analysis may show pretext when the prosecutor’s stated reason for striking a Black juror applies equally to white jurors who were not struck.
- Implausible or weak explanations, evaluated in light of the full voir dire record, can support a finding of purposeful discrimination under the Equal Protection Clause.

## Conclusion

The Court held that the State’s proffered reasons for striking a Black prospective juror were not credibly supported and were undermined by disparate treatment of comparable white jurors, making the trial court’s denial of the Batson challenge clearly erroneous; the conviction and death sentence were reversed and the case was remanded.


Snyder v. Louisiana, 552 U.S. 472 (2008)