Trevino v. Texas
Headline: Court reverses death sentence after prosecutors excluded Black jurors without race-neutral reasons, applies Batson rule and sends case back for further proceedings, increasing scrutiny of racial jury strikes.
Holding: The Court held that the defendant preserved an equal-protection objection to race-based peremptory strikes and is entitled to Batson’s rule on direct review, so the conviction was reversed and remanded.
- Requires prosecutors to state race-neutral reasons when jurors are struck.
- Gives defendants on direct appeal access to Batson protection.
- Can lead to new hearings or other proceedings when jurors were excluded by race.
Summary
Background
A Hispanic man was tried for murder and rape and faced the death penalty. Before the trial he filed a motion asking the court to forbid the State from using its peremptory jury strikes to remove people because of race. During jury selection the prosecutor used peremptory strikes to remove the only Black members of the panel, producing an all-white jury. The trial court denied the motion, and the Texas Court of Criminal Appeals later affirmed the conviction and death sentence.
Reasoning
The central question was whether the defendant had properly raised a constitutional equal-protection claim about race-based jury strikes and therefore was entitled to the protection announced in the Court’s recent Batson decision. The Court explained that the defendant’s pretrial motion and trial arguments — including a reference to a history of racial exclusion and to Swain — were enough to present an equal-protection claim to the trial court. Relying on Ford and other prior rulings, the Court held the defendant preserved his claim and is entitled to Batson’s rule on direct review, so the conviction must be reversed and the case returned for proceedings consistent with that rule.
Real world impact
This ruling requires courts to consider race-based jury-strike objections that were raised before Batson and gives defendants on direct appeal the benefit of Batson’s protection. It also means prosecutors will face closer review when jurors from a racial group are repeatedly struck. The case is sent back to the state courts for further proceedings that follow the Batson framework.
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