This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Defendant was accused of a crime and challenged the State's use of a peremptory strike to exclude the only Black member of the jury venire. The State justified the strike by citing the juror's failure to respond to questions about family members with felony convictions and potential connections to law enforcement witnesses. The juror later testified that she misunderstood the questions and felt uncomfortable discussing her family in a group setting.
Procedural History
- State v. Moore, 109 N.M. 119, 782 P.2d 91 (Ct. App. 1989): The Court of Appeals remanded the case to the district court for a hearing under Batson v. Kentucky to determine whether the State's peremptory challenge was racially motivated.
- District Court, post-remand: The district court held a hearing and concluded that the State provided clear, specific, and racially neutral reasons for the peremptory strike.
Parties' Submissions
- Defendant-Appellant: Argued that the State's peremptory challenge was racially discriminatory, as the prosecutor treated the excluded juror differently from white jurors who were not struck.
- Plaintiff-Appellee (State): Asserted that the peremptory challenge was based on the juror's failure to respond to questions about family members with felony records and her potential connection to a law enforcement witness, which were racially neutral reasons.
Legal Issues
- Did the State provide a racially neutral explanation for its peremptory challenge of the only Black juror on the venire?
Disposition
- The Court of Appeals affirmed the district court's decision, holding that the State's peremptory challenge was racially neutral and valid.
Reasons
Per Minzner J. (Bivins and Hartz JJ. concurring):
The Court found that the district court's determination that the State's reasons for the peremptory challenge were racially neutral was supported by substantial evidence. The prosecutor's explanation—that the juror failed to respond to relevant voir dire questions and had family members with felony records—was deemed clear, specific, and related to legitimate jury selection criteria. The Court emphasized that the prosecutor's concern about the juror's lack of candor was reasonable and not indicative of racial bias. The Court distinguished this case from others where discriminatory intent was inferred due to inconsistent treatment of jurors.