Hastings v. State
The Fourth DCA reversed a resisting-without-violence conviction after the trial court erroneously overruled a defense peremptory strike against a prospective juror during a Melbourne inquiry, finding the trial court erred at both step 2 (wrongly concluding the proffered reasons—juror's trust in police and CSI viewership—were not race-neutral) and step 3 (failing to require the State to carry its burden of persuasion on genuineness). The court held the record did not support a finding of pretext, particularly given the absence of any evidence about the racial composition of the venire or disparate treatment of similarly-situated jurors.
Key facts
- Hastings was convicted of resisting arrest without violence in the trial court.
- During voir dire, the trial court overruled a defense peremptory challenge against a prospective juror, relying on the juror's expressed trust in police and interest in crime-related television shows as reasons to deny the strike.
- +2 more key facts with a free trial
Why it matters
This opinion provides a clear, citable roadmap for Melbourne/Batson step 2 and step 3 analysis, reinforcing that generic responses about trusting police or watching crime shows are race-neutral and cannot support a… — full analysis with a trial
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