476 U.S. 79 (1986)
Batson v. Kentucky marks a watershed in American jury selection law.
Does the Equal Protection Clause prohibit a prosecutor from using peremptory challenges to strike prospective jurors solely on account of their race, and may a criminal defendant establish a prima facie case of such discrimination based on the prosecutor's actions in the defendant's own trial without showing a historical pattern across cases?
Purposeful racial discrimination in the use of peremptory challenges violates the Equal Protection Clause. A trial court must apply a three-step framework: (1) the defendant must make a prima facie showing that the prosecutor exercised peremptory strikes on the basis of race by pointing to facts and circumstances that raise an inference of discriminatory purpose; (2) if that showing is made, the burden shifts to the prosecutor to articulate a clear, reasonably specific, race-neutral explanation for each challenged strike that is related to the case; and (3) the court then determines whether the defendant has proven purposeful discrimination, assessing the credibility of the proffered reasons and the totality of the circumstances. A mere denial of discriminatory motive or reliance on racial stereotypes is insufficient; reasons must be facially race-neutral, and the trial court's finding on intent is entitled to great deference on appeal.
Yes. The Equal Protection Clause forbids prosecutors from challenging potential jurors solely on account of their race or on the assumption that jurors of a particular race will be biased. A defendant may establish a prima facie case of discriminatory jury selection based solely on the prosecutor's peremptory strikes in the defendant's own trial. Swain v. Alabama is overruled in part. The judgment was reversed and the case remanded for application of the new standard.
Batson revolutionized voir dire by making discriminatory peremptory strikes reviewable in real time and by crafting a workable evidentiary framework that trial courts use daily. For law students, Batson is essential to understanding equal protection doctrine within criminal procedure, evidentiary burdens and shifting frameworks, and the interaction between individual rights and institutional practices. The decision has been extended to civil cases (Edmonson v. Leesville Concrete), to peremptories by criminal defendants (Georgia v. McCollum), to cross-racial claims where the defendant and excluded jurors are of different races (Powers v. Ohio), and to gender-based strikes (J.E.B. v. Alabama). It also sets the stage for later cases refining what counts as a valid race-neutral reason, how trial courts assess pretext, and the deference reviewing courts give to those determinations.