Colorado v. RodriguezAnnotate this Case
The issue this case presented for the Colorado Supreme Court's review centered on how both trial and appellate courts should determine whether a party has used a peremptory challenge to purposefully discriminate against a prospective juror on account of her race, in violation of the U.S. Supreme Court’s rule in "Batson v. Kentucky," (476 U.S. 79 (1986)). The State charged respondent Romielo Rodriguez with three counts of felony menacing after his neighbors alleged that he and a co-defendant pointed guns at them during a dispute. Rodriguez pled not guilty, and his trial began in August 2009. During jury selection, the prosecutor used his first peremptory strike to excuse Ms. D., a black woman. Rodriguez raised a Batson objection, but the juror was excused nonetheless. Rodriguez raised another Batson objection when the prosecutor used his second peremptory strike to excuse Ms. A., who has a Hispanic surname. On her juror questionnaire, Ms. A. had stated that she was affiliated with a church. Ms. A. was also dismissed. The prosecution exercised three more peremptory challenges, and Rodriguez used all six available to him. The trial court denied Rodriguez' Batson-challenged jurors for lack of a pattern of strikes against members of a cognizable racial group. The court of appeals reversed Rodriguez’s convictions and ordered a new trial because it held that the trial court clearly erred by denying Rodriguez’s Batson challenges for failure to show a pattern of discrimination. The Colorado Court granted the State's petition for certiorari to review the court of appeals’ decision to reverse Rodriguez’s convictions and order a new trial. After review, the Court reversed, holding that the proper remedy for an inadequate inquiry into a Batson challenge at the time of jury selection was to remand the case to the trial court with directions to conduct the three-part Batson analysis and make the required factual findings. An inadequate Batson inquiry occurs when the trial court’s findings are insufficient to determine whether the opponent of the peremptory strike has proved that the proponent used the strike to purposefully discriminate against prospective jurors at issue. The case was remanded for the trial court to conduct the three-part Batson analysis.