Rodney Howard v. United States
JusticiabilityDoctri
1. Does a black defendant make a prima facie showing of discriminatory use of peremptory strikes under Batson's first step when he demonstrates that the prosecution has used peremptory strikes to remove the only two black prospective jurors from the venire?
2. Where the district court does not reach Batson's third step, and offers contradictory assessments of the prosecutor's stated reason for a strike, should a reviewing court defer to the district court's finding of record support for the stated reason for the strike or instead consider all record evidence to determine whether the peremptory strike was the product of race discrimination?
Does a black defendant make a prima facie showing of discriminatory use of peremptory strikes under Batson's first step when he demonstrates that the prosecution has used peremptory strikes to remove the only two black prospective jurors from the venire?