Colorado v. MadridAnnotate this Case
In 2011, Respondent Theodore Madrid was charged with one count of first degree murder and two counts of child abuse resulting in death. During jury selection, the prosecution excused prospective juror J.T., a Black man who indicated on his juror questionnaire that he was sixty-eight years old, married with children, and a retired customer-service specialist. The court gave each side a total of five minutes to question the prospective jurors, including J.T. The prosecution asked J.T. if he had any concerns about potentially having to look at autopsy pictures in the case, to which J.T. responded, "no." The prosecution then asked J.T., "Do you have a good joke?" J.T. responded, "I'm the joke." Thereafter, the prosecution used its ninth peremptory challenge to excuse J.T. Madrid raised a Batson challenge to this, arguing the excuse was race-neutral: "the real problem is we don’t know very much about him. He has a hearing issue it appears and he’s sort of completely nonresponsive. We have very little information on him from the questionnaire and no time to really have a very detailed conversation with him." The trial court accepted this reason and excused the juror. After a nine-day trial, the jury convicted Madrid on all counts. The issue this case presented for the Colorado Supreme Court's review on whether a party could, on remand, raise a new race-neutral reason to justify a peremptory strike made at trial. The Supreme Court responded in the negative: when a party has been provided with an adequate opportunity to present its race-neutral justifications at trial, it is barred from introducing new race-neutral justifications on remand. The Court's application of that holding to the facts here prompted the Court to affirm the court of appeals' judgment, which meant that Madrid was entitled to a new trial.