Hernandez v. New York, 500 U.S. 352 (1991)
Hernandez v. New York engages the core principles of equal protection in the context of jury selection, scrutinizing whether race-based use of peremptory challenges contravenes the Constitution.
Whether the prosecutor's use of peremptory challenges to strike Hispanic jurors based on concerns about bilingual biases violated the Equal Protection Clause.
A prosecutor may use peremptory challenges, but if challenged, must offer a race-neutral explanation for the strikes; the burden then shifts to the opponent to prove intentional discrimination.
The Supreme Court held that the prosecutor's explanation for striking the jurors—their potential bias regarding the interpreter's translation—was race-neutral. The trial court's acceptance of this explanation, grounded in the record, was not clearly erroneous.
Hernandez v. New York is a landmark case, reinforcing the framework established in Batson v. Kentucky. It underscores the necessity for defendants to substantiate claims of discriminatory intent beyond the provision of race-neutral explanations by prosecutors. This case illustrates the complexities inherent in judicial determinations of discrimination and the latitude afforded to trial courts in assessing and interpreting prosecutorial intent. For law students, the case highlights the procedural and evidentiary challenges inherent in claims of racial discrimination in jury selection.