State v. BennettAnnotate this Case
The Supreme Court reversed the decision of the court of appeals affirming superior court judgments denying Defendant's Batson motion, holding that Defendant presented a sufficient record to permit meaningful appellate review of Defendant's Batson challenge and that Defendant established the existence of a prima facie case of discrimination necessary to require the performance of a complete Batson analysis.
The trial court allowed Defendant to make a Batson motion but subsequently denied the motion, finding that there was no prima facie showing justifying the Batson challenge. The court of appeals also rejected Defendant's Batson claim, stating that, "[a]ssuming, arguendo, that defendant's argument is properly before us, we find no error in the ruling of the trial court and affirm." The Supreme Court reversed and remanded the case for further proceedings in the superior court, holding (1) the record was sufficient to permit appellate review of the merits of Defendant's Batson claim; and (2) the trial court erred in failing to find the existence of a prima facie showing of racial discrimination.