City of Seattle v. Erickson (Majority and Concurrence)Annotate this Case
Trial courts must engage in a full Batson analysis when a peremptory strike of a juror is the only member of a cognizable racial group. In 2013, Petitioner Matthew Erickson, a black man, was charged in Seattle Municipal Court with unlawful use of a weapon and resisting arrest. After voir dire, the city of Seattle (City) exercised a peremptory challenge against the only black juror on the jury panel. After the jury was empaneled and excused from the courthouse with the rest of the venire, Erickson objected to the peremptory challenge, claiming the strike was racially motivated. The court found that there was no prima facie showing of racial discrimination and overruled Erickson's objection. Batson v. Kentucky, 476 U.S. 79, (1986), guarantees a jury selection process free from racial animus. Yet, the Washington Supreme Court noted that Washington's Batson protections were "not robust enough" to effectively combat racial discrimination during jury selection. The Court used the opportunity of this opinion to "better effectuate the equal protection guaranties espoused in Batson." The Court amended Washington's Batson framework and held that the peremptory strike of a juror who is the only member of a cognizable racial group constitutes a prima facie showing of racial discrimination requiring a full Batson analysis by the trial court.