Colorado v. WilsonAnnotate this Case
This case centered on appropriate resolution of a Batson challenge. Petitioner Derrick Wilson objected to the prosecutor’s use of a peremptory strike to excuse a black veniremember and argued that the strike violated the Equal Protection Clause of the Fourteenth Amendmen tas interpreted in "Batson v. Kentucky," (476 U.S. 79 (1986)). The trial court 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 State appealed, and the Colorado Supreme Court reversed. 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 pursuant to 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."