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 convicted of trafficking cocaine and conspiracy to traffic cocaine. During jury selection, the prosecution used all its peremptory challenges to exclude Hispanic men, raising concerns about racial and gender discrimination. The jury ultimately consisted of four Hispanics, one Native American, and seven Anglos, with eleven women and one man (paras 4-6).
Procedural History
- District Court, Taos County: The Defendant was convicted of trafficking cocaine and conspiracy to traffic cocaine. The trial court denied motions to dismiss the charges or the jury based on alleged discriminatory use of peremptory challenges (paras 1, 6-7).
Parties' Submissions
- Defendant-Appellant: Argued that the prosecution's use of peremptory challenges constituted purposeful discrimination against Hispanics, violating the Equal Protection Clause of the Fourteenth Amendment, and against men, violating Article II, Sections 14 and 18 of the New Mexico Constitution (para 8).
- Plaintiff-Appellee: Contended that the trial court correctly determined the Defendant failed to make a prima facie case of discrimination and that the jury composition was not substantially underrepresented (para 8).
Legal Issues
- Did the prosecution's use of peremptory challenges violate the Equal Protection Clause by systematically excluding jurors based on race?
- Did the prosecution's use of peremptory challenges violate the New Mexico Constitution by systematically excluding jurors based on gender?
- Was the Defendant's right to a jury reflecting a fair cross-section of the community infringed?
Disposition
- The case was remanded to the trial court for a hearing to determine whether the prosecution's peremptory challenges were used to systematically exclude jurors based on race or gender. If intentional discrimination is found, the convictions are to be reversed, and a new trial ordered. If not, the convictions will stand (paras 41-42).
Reasons
Per Chavez J. (Donnelly and Apodaca JJ. concurring):
Racial Discrimination: The trial court erred in requiring the Defendant to show substantial underrepresentation of Hispanics on the jury to establish a prima facie case. Under Batson v. Kentucky, a prima facie case can be made by showing a pattern of strikes against a racial group. The Defendant demonstrated that the prosecution used 80% of its peremptory challenges to exclude Hispanic men, which shifted the burden to the prosecution to provide race-neutral explanations (paras 13-22).
Gender Discrimination: The court extended the rationale of State v. Aragon to prohibit gender-based peremptory challenges under Article II, Sections 14 and 18 of the New Mexico Constitution. The prosecution's use of all its peremptory challenges to exclude men raised an inference of gender discrimination. The trial court must now evaluate whether the prosecution's actions were intentionally discriminatory (paras 26-35).
Remand Instructions: The trial court must hold a hearing where the prosecution must provide race- and gender-neutral explanations for its peremptory challenges. The trial court will then determine whether the challenges were discriminatory. If so, the convictions will be reversed, and a new trial ordered (paras 23, 25, 41-42).