Also known as: race neutral explanation · racially neutral explanation · race-neutral explanations
Written by attorneys · grounded in primary & secondary sources — see below
A justification offered by a party exercising a peremptory challenge that does not rely on the race of the prospective juror. The justification must be clear and reasonably specific. It need not be persuasive or plausible at the second step of the inquiry.
Roger Ramirez stood trial for theft. The prosecutor struck two Black jurors who worked in software. When defense counsel raised a Batson objection, the prosecutor stated that the jurors' technical backgrounds might create sympathy for digital evidence issues. The court accepted the explanation as race-neutral and overruled the objection.
Roland Rhodes faced charges in state court. His counsel used peremptory challenges to remove all Black venire members. The prosecutor objected and demanded a race-neutral explanation. Defense counsel responded that the jurors appeared too sympathetic to law enforcement based on their answers during voir dire.
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Ravi Reddy sued Ridgeway Partners for contract damages. The defense struck every Black prospective juror. Reddy objected on equal protection grounds. The court required Ridgeway's counsel to articulate a race-neutral explanation tied to the jurors' responses rather than their race.
Renata Russo challenged her conviction years later on the ground that the prosecutor had failed to supply race-neutral explanations for strikes. The reviewing court held that the requirement for such explanations did not apply retroactively to cases already final on direct review.
Rosalind Reed challenged a legislative district map as racially gerrymandered. The state defended the lines by asserting race-neutral political considerations. The court examined whether the offered explanation was credible or merely a pretext for racial sorting of voters.
A party must first establish a prima facie case by showing a pattern of strikes against members of a cognizable racial group that raises an inference of discrimination. Once that showing is made, the burden shifts to the striking party to articulate a race-neutral explanation.
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No. The explanation need only be clear, reasonably specific, and facially race-neutral. The persuasiveness of the reason is assessed only at the third step when the court determines whether purposeful discrimination has been proven.
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Yes. Jury selection is a traditional governmental function conducted under court supervision. A private litigant exercising peremptory challenges therefore engages in state action and must supply a race-neutral explanation when a prima facie case of discrimination is shown.
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The court must sustain the objection, disallow the discriminatory strikes, and apply an appropriate remedy such as reseating the improperly struck jurors or beginning jury selection anew.
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…whether a prima facie case of racial discrimination has been established in the case before us, requiring Leesville to offer race-neutral explanations for its peremptory challenges. In Batson , we held that determining whether a prima facie case has been established requires consideration of all relevant circumstances, including whether…