State v. Holmes
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The Supreme Court affirmed the judgment of the Appellate Court upholding Defendant's conviction of felony murder on the basis of its rejection of his claim brought under Batson v. Kentucky, 476 U.S. 79 (1986), holding that that the Appellate Court properly affirmed the judgment of conviction but systemic concerns about Batson's failure to address the effects of implicit bias and disparate impact must be referred to a Jury Selection Task Force.
Defendant was convicted of felony murder. The Appellate Division affirmed, holding (1) there was no adequate claim that the Appellate Court improperly upheld the trial court's finding that the prosecutor's reasons were not pretextual under the third step of Batson; and (2) although the relief the Court could provide was constrained by Defendant's decision to limit his Batson claims to the Equal Protection Clause, the broader themes of disparate impact and implicit bias that Defendant advanced raised enough concern with the fairness of the criminal justice system for measures to be concerned intended to promote the selection of diverse jury panels in the state's courthouses.
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