Blackman v. Texas (Original)Annotate this Case
A jury convicted appellant of felony possession with intent to deliver cocaine in an amount over 400 grams. The trial court sentenced him to thirty years' confinement in the penitentiary. Appellant argued on appeal that the trial court erred to overrule his objection that the State used a peremptory challenge to strike an African-American prospective juror from service on his petit jury in violation of "Batson v. Kentucky." The court of appeals agreed, finding that at least one of the prosecutor's purported explanations for the peremptory challenge was a pretext for racial discrimination, and reversed the appellant's conviction. The State petitioned for discretionary review. Upon review, the Court of Criminal Appeals concluded that the court of appeals' reliance upon "Snyder v. Louisiana" on the particular facts of this case was in error: "Simply put, the court of appeals erred to conclude that Snyder governs the facts of this case. In our view, the court of appeals' analysis went wrong" by: (1) misinterpreting the prosecutor's proffer of racially neutral explanations for striking the juror in question to include two non-demeanor-based reasons; (2) concluding that the trial court made no ruling with respect to the prosecutor's demeanor-based explanations for his peremptory challenge; and (3) shifting the burden of proof to the State, a la Snyder, to rebut an inference that these purported explanations conclusively established discrimination.