Louisiana v. Bender
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The State charged defendant with one count of simple burglary of a vehicle. The issue on appeal, presented for the Supreme Court's review centered on whether the District Court's failure to observe the strictures of a rule jurisprudentially created by the Fourth Circuit in "Louisiana v. Knighten," (609 So.2d 950 (La. App. 4 Cir. 1992)), constituted a violation of the defendant's equal protection and due process rights under "Batson v. Kentucky," (106 S.Ct. 1712 (1986)), requiring a reversal of the jury's guilty verdict. Following voir dire, defendant raised Batson challenges relative to three of the State's peremptory strikes. After hearing the State's proffered race-neutral reasons, the District Court denied defendant's Batson challenges. Citing the State's failure to follow the so-called "Knighten rule," the Court of Appeal reversed defendant's conviction and sentence and remanded the case for a new trial. The Supreme Court found the
"Knighten rule" undermined the well-established Batson framework the Louisiana Court adopted and repeatedly applied. Therefore, the Court reversed the Court of Appeal, reinstated defendant's conviction and sentence, and overruled Knighten insofar as it establishes the "Knighten rule."
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