Colorado v. WilsonAnnotate this Case
Petitioner Derrick Wilson objected to the prosecutor's use of a peremptory strike to excuse a black veniremember, arguing that the strike violated the Equal Protection Clause of the Fourteenth Amendment as interpreted in "Batson v. Kentucky," (476 U.S. 79 (1986)). The trial court then allowed the prosecutor to articulate a race-neutral reason for the strike. She explained that the prospective juror appeared uncomfortable with DNA evidence and the lack of eyewitness identification. Defense counsel responded that the prospective juror's responses indicated "the exact opposite," but the trial court accepted the prosecutor's explanation and denied Wilson's Batson challenge. The jury later found Wilson guilty of sexual assault, second-degree kidnapping, and unlawful sexual contact. Wilson appealed, and the court of appeals held that the trial court clearly erred in denying his Batson challenge. The issue this case presented for the Supreme Court's review was the appropriate resolution of a Batson challenge. After review, the Court held that a prosecutor's error in recollection did not compel a finding of purposeful discrimination in contravention of the Equal Protection Clause as interpreted by Batson. "Rather, the Batson analysis requires the trial court to assess the credibility of the proponent of a peremptory strike and determine whether to believe her race-neutral explanation. Unless the opponent of the strike can prove purposeful discrimination, the trial court should deny the Batson challenge. On appeal, a reviewing court should defer to the trial court's credibility determination and reverse only for clear error." The Court concluded the trial court in this matter did not clearly err by denying Wilson's Batson challenge, and reversed the Court of Appeals.