Alvarado v. United States
Headline: Racial jury-selection dispute leads Court to vacate and send the conviction back for reconsideration after the government says the appeals court used the wrong approach to Batson claims, affecting how such claims are reviewed.
Holding: The Court granted review, vacated the appeals court’s judgment, and remanded for reconsideration because the United States said the appeals court relied on an incorrect approach to Batson claims.
- Sends the conviction back to the appeals court for reconsideration of alleged racial jury strikes.
- Confirms that Government statements in this Court can prompt the Court to vacate and send cases back.
- Dissent warns this practice may discourage frank government briefs in future cases.
Summary
Background
A criminal defendant argued that prosecutors used peremptory strikes to remove black jurors only because of race, citing Batson v. Kentucky. The trial court accepted the prosecutors’ explanations and the defendant was convicted. The Court of Appeals affirmed without deciding the competing factual claims because it held no appellate inquiry was required if the chosen jury represented a fair cross section of the community. The defendant asked the Supreme Court to review the case and was allowed to proceed without paying fees.
Reasoning
The United States told the Supreme Court that the appeals court had relied on the wrong legal approach by treating the fair-cross-section idea as a bar to a Batson inquiry. The Government also said the appeals court’s reasoning was undermined by a later decision, Holland v. Illinois. But the Government simultaneously argued that the defendant had not proved purposeful discrimination and that the reasons for the strikes were race-neutral. Because the Government pointed out that the appeals court rested its decision on an improper ground, the Supreme Court granted review, vacated the appeals court’s judgment, and sent the case back for reconsideration in light of the Government’s position.
Real world impact
The appeals court must now reexamine whether prosecutors struck jurors because of race. The ruling does not decide the underlying discrimination claim on the merits. The Supreme Court’s action follows its practice of vacating and remanding when the Government identifies a legal error.
Dissents or concurrances
Chief Justice Rehnquist, joined by three Justices, dissented. He warned that vacating a decision when the Government has not formally confessed error may chill candor in future Government briefs and is unwise.
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