Snyder v. Louisiana
The Supreme Court threw out a Louisiana man's death sentence, ruling that the trial judge should have caught that a prosecutor's stated reasons for striking a Black juror did not hold up and likely masked racial bias.
The decision reinforces that judges must carefully test prosecutors' explanations for excluding jurors of a particular race, especially when those explanations don't survive comparison to how similar white jurors were treated.
“For these reasons, we cannot presume that the trial judge credited the prosecutor’s assertion that Mr. Brooks was nervous.”
The Court explains why it cannot assume the judge relied on the claim that the juror looked nervous.
How it got here: The Louisiana Supreme Court twice rejected Snyder's claim that the strikes were racially motivated; the U.S. Supreme Court took the case after an earlier remand for reconsideration in light of a related ruling.
The Case in Depth
What happened
Allen Snyder, a Black man, was convicted of first-degree murder in Louisiana and sentenced to death for killing his estranged wife's date. During jury selection, prosecutors used peremptory strikes to remove all five Black prospective jurors who survived challenges for cause, including a college student named Jeffrey Brooks who was completing a student-teaching requirement.
The question before the Court
Did a prosecutor illegally use race to strike a Black juror in a death penalty trial, in violation of the Constitution's ban on racial discrimination in jury selection?
The Court's answer
Yes — the Court ruled that the trial judge should have rejected the prosecutor's strike of Mr. Brooks because the prosecutor's stated reasons did not hold up. The Court could not assume the judge actually relied on the claim that Brooks seemed nervous, since the judge gave no explanation for the ruling and the strike came a day after Brooks was questioned, among dozens of others.
The prosecutor's other reason — that Brooks's student-teaching schedule might rush him toward a lenient verdict to avoid a lengthy trial — made no sense once the timeline was examined: the trial ended quickly, and Brooks's dean had already said he would accommodate any missed classes. That implausible explanation, especially next to white jurors with similar conflicts who were not struck, pointed to racial discrimination, so the strike could not stand.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Prosecutors across the country routinely offer 'race-neutral' reasons for striking jurors, and trial judges often accept them with little scrutiny. This ruling tells judges they must actually test whether those reasons make sense and hold up against how other jurors of a different race were treated, or risk having convictions and death sentences overturned.
What changes now
The case goes back to the Louisiana courts for further proceedings consistent with the ruling. Because the Court found a constitutional violation in jury selection, Snyder's conviction and death sentence cannot stand as they are; Louisiana would need to retry him with a properly selected jury if it wishes to pursue the case further. This is a final decision on the merits, not a temporary order.
What this does not decide
The Court did not decide whether striking the juror based on nervousness alone, standing apart from the discredited second reason, would have been constitutional. It also left open whether, in these cases, showing discrimination played some role always shifts the burden to prosecutors to prove it wasn't decisive.
Concurrences and dissents
Dissent — Justice Thomas
“None of the evidence in the record as to jurors Jeffrey Brooks and Elaine Scott demonstrates that the trial court clearly erred in finding they were not stricken on the basis of race.”Thomas argues the record does not show the trial judge was clearly wrong to reject the discrimination claim.
Justice Thomas argued the majority second-guessed a fact-based credibility call that belongs to the trial judge, who personally observed the juror and prosecutor. He faulted the majority for assuming the judge relied on the pretextual reason rather than the nervousness the record actually hinted at, and objected to using a juror comparison never raised below. He would have deferred to the trial court and affirmed the conviction and sentence.
How the Court got there
The legal reasoning, step by step
- The Court applied the three-step framework for evaluating claims that a juror was struck because of race: the defendant must first show the strike looks racially motivated, then the prosecutor must give a race-neutral reason, and finally the judge must decide if that reason is genuine or a cover for discrimination.
- Appellate courts must accept a trial judge's ruling on this question unless it is clearly wrong, because the judge who watched the jury questioning in person is best positioned to size up whether the prosecutor and juror were being truthful about things like nervous demeanor.
- The Court found it could not assume the judge actually relied on the claim that the juror looked nervous, since the judge ruled with no explanation and the strike came a full day after the juror was questioned, among dozens of others.
- Testing the prosecutor's second reason—that the juror's need to finish student teaching might make him rush to a lesser verdict—the Court found it made no logical sense given how quickly the trial in fact ended, and how the juror's school dean had already said he would accommodate missed time.
- The Court found this implausible reason especially suspicious because the prosecutor had not struck two white jurors who had described comparable or more serious scheduling conflicts, which pointed toward pretext.
- Because the explanation for striking this one juror was pretextual, the Court concluded discrimination had tainted the strike, and it declined to explore on remand, more than a decade later, whether the juror's nervousness alone might have justified the strike anyway.
Doctrinal impact
Cases affected by this decision
Reaffirms Batson v. Kentucky (476 U. S. 79)
The Court applies and reaffirms Batson's three-step test for spotting racial discrimination in jury strikes.
Reaffirms Miller-El v. Dretke (545 U. S. 231)
The Court reaffirms that all circumstances bearing on racial animosity must be considered together in a Batson challenge.