Snyder v. Louisiana

Background

A man convicted of first-degree murder in Louisiana was sentenced to death after a jury trial. During jury selection the prosecutor used peremptory strikes to remove all five Black prospective jurors who had survived challenges for cause. The Supreme Court focused on one juror, Jeffrey Brooks, a college senior doing required student teaching, who was excused after the prosecutor said Brooks appeared nervous and had a class conflict. A law clerk called Brooks’ dean, who said he could work with Brooks.

Reasoning

The Court applied Batson’s three-step test for racial exclusions and stressed that trial judges must evaluate prosecutor demeanor and juror demeanor when deciding credibility. Here the trial judge allowed the challenge without explaining which reason he credited. The Court found no record evidence that the judge relied on Brooks’ nervousness and found the school-conflict explanation implausible because Brooks’ dean said the missed days could be made up and the trial was short. The prosecutor had accepted white jurors who reported comparable scheduling problems. Because the stated reason did not hold up, the Court inferred racial motivation and found clear error.

Real world impact

The ruling reverses the state court’s decision and sends the case back for further proceedings. It makes it harder for prosecutors to rely on flimsy explanations to exclude Black jurors and signals that appellate courts will scrutinize peremptory strikes where similar unstruck white jurors exist.

Dissents or concurrances

Justice Thomas, joined by Justice Scalia, dissented, arguing the trial judge’s credibility call should be respected and that the Court improperly second-guessed fact findings.