1. Whether expressly linking a black juror's remark in a jury questionnaire
indicating that he had an "unpleasant experience" with police (namely, "driving while
black") to the fact the defendant is also black and involved in the criminal justice
system constitutes a "race-neutral" justification for peremptorily striking the juror
under Batson v. Kentucky, 476 U.S. 79 (1991), in the absence of any direct evidence
that the juror mistrusted police or harbored negative feelings about the criminal
justice system?

2. Whether back-to-back peremptory strikes of two black jurors, resulting in the
empanelment of an all-white jury in a racially-charged homicide case, runs afoul of
the "all relevant facts and circumstances" analysis set forth in Flowers v. Mississippi,
588 U.S. 284 (2019), when (i) the first juror was struck on the basis of a combination
of plainly race-based and dubious race-neutral reasons, and (ii) the second juror was
subjected to a lengthy inquisition concerning her ability to fairly sit in judgment of a
black defendant, only to be struck on ostensibly race-neutral grounds the trial court
had previously found incredible?

Whether expressly linking a black juror's remark in a jury questionnaire indicating that he had an 'unpleasant experience' with police (namely, 'driving while black') to the fact the defendant is also black and involved in the criminal justice system constitutes a 'race-neutral' justification for peremptorily striking the juror under Batson v. Kentucky, 476 U.S. 79 (1991), in the absence of any direct evidence that the juror mistrusted police or harbored negative feelings about the criminal justice system?