discriminatory challenge (California) · Go Syfert
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discriminatory challenge in California

8 California opinions name it 2 courts 1967–2022 1 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
People v. Williamsgreen
cal · 2006 · cited in 2 California opinions naming this issue, 2015–2022
2 sentences

2022(See People v. Winbush (2017) 2 Cal.5th 402, 443 [pretext is established “when the compared jurors have expressed ‘a substantially similar combination of responses,’ in all material respects”], original italics.) This is particularly true here, where there is a single discriminatory challenge, the record reveals a “ ‘sound, objectively plausible basis’ ” for the challenge,6 and we must credit “ ‘the legitimate role that subjective factors may have in a prosecutor’s decision’ to challenge or not challenge jurors peremptorily.” (People v. Williams (2006) 40 Cal.4th 287, 313 .) Thus, a comparison

2015Because “a Wheeler/Batson violation may occur with a single discriminatory challenge” (People v. Williams (2006) 40 Cal.4th 287, 313 (Williams)), the trial court erred in relying on a categorical rule that a solitary challenge cannot.

12
People v. Winbushgreen
cal · 2017 · cited in 1 California opinions naming this issue, 2022–2022
1 sentence

2022(See People v. Winbush (2017) 2 Cal.5th 402, 443 [pretext is established “when the compared jurors have expressed ‘a substantially similar combination of responses,’ in all material respects”], original italics.) This is particularly true here, where there is a single discriminatory challenge, the record reveals a “ ‘sound, objectively plausible basis’ ” for the challenge,6 and we must credit “ ‘the legitimate role that subjective factors may have in a prosecutor’s decision’ to challenge or not challenge jurors peremptorily.” (People v. Williams (2006) 40 Cal.4th 287, 313 .) Thus, a comparison

11
Crawford v. Board of Ed. of Los Angelesgreen
scotus · 1982 · cited in 1 California opinions naming this issue, 2007–2007
2 sentences

2007In sum, the simple repeal or modification of desegregation or antidiscrimination laws, without more, never has been viewed as embodying a presumptively invalid racial classification." ( Id. at pp. 538-539, 102 S.Ct. 3211 .) However, where the purpose for repealing legislation is to disadvantage a racial minority, the repeal is unconstitutional. ( Id. at p. 539, fn. 21, 102 S.Ct. 3211 .) Countering the argument that Proposition I fundamentally altered the judicial system by leaving those seeking relief from racial isolation in violation of state law with less than full judicial relief, the cour

2007In sum, the simple repeal or modification of desegregation or antidiscrimination laws, without more, never has been viewed as embodying a presumptively invalid racial classification." ( Id. at pp. 538-539, 102 S.Ct. 3211 .) However, where the purpose for repealing legislation is to disadvantage a racial minority, the repeal is unconstitutional. ( Id. at p. 539, fn. 21, 102 S.Ct. 3211 .) Countering the argument that Proposition I fundamentally altered the judicial system by leaving those seeking relief from racial isolation in violation of state law with less than full judicial relief, the cour

11
Miller-El v. Dretkegreen
scotus · 2005 · cited in 1 California opinions naming this issue, 2006–2006
2 sentences

2006Our confidence in the results of appellate comparative analysis is somewhat diminished when there is a "lone questionable peremptory challenge" and the record reveals "a sound, objectively plausible basis" for the challenge. ( People v. Jackson (1996) 13 Cal.4th 1164, 1254 , 56 Cal.Rptr.2d 49 , 920 P.2d 1254 (cone, opn of Mosk, J.) ( Jackson ).) Moreover, C.K. was the only Black juror to be peremptorily challenged: (Cf. Miller-El v. Dretke, supra, 545 U.S. 231, 241 , 125 S.Ct. 2317, 2325 , 162 L.Ed.2d 196 [10 Black prospective jurors struck and one on panel].) Although, to be sure, a Wheeler/B

2006Our confidence in the results of appellate comparative analysis is somewhat diminished when there is a "lone questionable peremptory challenge" and the record reveals "a sound, objectively plausible basis" for the challenge. ( People v. Jackson (1996) 13 Cal.4th 1164, 1254 , 56 Cal.Rptr.2d 49 , 920 P.2d 1254 (cone, opn of Mosk, J.) ( Jackson ).) Moreover, C.K. was the only Black juror to be peremptorily challenged: (Cf. Miller-El v. Dretke, supra, 545 U.S. 231, 241 , 125 S.Ct. 2317, 2325 , 162 L.Ed.2d 196 [10 Black prospective jurors struck and one on panel].) Although, to be sure, a Wheeler/B

11
Connecticut v. Tealgreen
scotus · 1982 · cited in 1 California opinions naming this issue, 1987–1987
2 sentences

1987First, as pointed out in Connecticut v. Teal, supra, the United States Supreme Court has “consistently focused on employment and promotion requirements that create a discriminatory bar to opportunities. [It] has never read [Title VII] as requiring the focus to be placed instead on the overall number of minority or female applicants actually hired or promoted.” (Id., 457 U.S. at p. 450 [ 73 L.Ed.2d at p. 139 ].) In any event, allowing an employer to avoid judicial scrutiny because the number of minorities actually promoted was too small would allow it to benefit from its own discriminatory prac

1987First, as pointed out in Connecticut v. Teal, supra, the United States Supreme Court has “consistently focused on employment and promotion requirements that create a discriminatory bar to opportunities. [It] has never read [Title VII] as requiring the focus to be placed instead on the overall number of minority or female applicants actually hired or promoted.” (Id., 457 U.S. at p. 450 [ 73 L.Ed.2d at p. 139 ].) In any event, allowing an employer to avoid judicial scrutiny because the number of minorities actually promoted was too small would allow it to benefit from its own discriminatory prac

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
People v. Jackson green
cal · 1996
2 sentences

2006Our confidence in the results of appellate comparative analysis is somewhat diminished when there is a "lone questionable peremptory challenge" and the record reveals "a sound, objectively plausible basis" for the challenge. ( People v. Jackson (1996) 13 Cal.4th 1164, 1254 , 56 Cal.Rptr.2d 49 , 920 P.2d 1254 (cone, opn of Mosk, J.) ( Jackson ).) Moreover, C.K. was the only Black juror to be peremptorily challenged: (Cf. Miller-El v. Dretke, supra, 545 U.S. 231, 241 , 125 S.Ct. 2317, 2325 , 162 L.Ed.2d 196 [10 Black prospective jurors struck and one on panel].) Although, to be sure, a Wheeler/B

2006Our confidence in the results of appellate comparative analysis is somewhat diminished when there is a "lone questionable peremptory challenge" and the record reveals "a sound, objectively plausible basis" for the challenge. ( People v. Jackson (1996) 13 Cal.4th 1164, 1254 , 56 Cal.Rptr.2d 49 , 920 P.2d 1254 (cone, opn of Mosk, J.) ( Jackson ).) Moreover, C.K. was the only Black juror to be peremptorily challenged: (Cf. Miller-El v. Dretke, supra, 545 U.S. 231, 241 , 125 S.Ct. 2317, 2325 , 162 L.Ed.2d 196 [10 Black prospective jurors struck and one on panel].) Although, to be sure, a Wheeler/B

12006–2006
Howlett Ex Rel. Howlett v. Rose green
scotus · 1990
1 sentence

1994For example, neutral procedural rules may be applied to federal claims (Howlett v. Rose, supra, 496 U.S. at p. 372 ) [110 L.Ed.2d at pp. 351-352]; stated differently, a discriminatory state requirement may violate the supremacy clause.

11994–1994
New York Shipping Ass'n v. Federal Maritime Commission neutral
· 1988
1 sentence

1992Cir. 1988) 854 F.2d 1338 [ 272 U.S.App.D.C. 129 ], The court in New York Shipping upheld a determination by the Federal Maritime Commission that in reviewing the validity of a discriminatory rule contained in a collective bargaining agreement, the commission could not rely on labor policy considerations (such as the interest in preserving work), but could consider only transportation conditions. (854 F.2d at pp. 1344, 1366, 1373, 1375.) The court reasoned as follows: the Shipping Act’s prohibition against unreasonable discriminatory practices is similar to prohibitions in the Interstate Commer

11992–1992
cluster 510613 green
· 1988
1 sentence

1992Cir. 1988) 854 F.2d 1338 [ 272 U.S.App.D.C. 129 ], The court in New York Shipping upheld a determination by the Federal Maritime Commission that in reviewing the validity of a discriminatory rule contained in a collective bargaining agreement, the commission could not rely on labor policy considerations (such as the interest in preserving work), but could consider only transportation conditions. (854 F.2d at pp. 1344, 1366, 1373, 1375.) The court reasoned as follows: the Shipping Act’s prohibition against unreasonable discriminatory practices is similar to prohibitions in the Interstate Commer

11992–1992
Western Addition Community Organization v. Alioto green
cand · 1973
1 sentence

1987First, as pointed out in Connecticut v. Teal, supra, the United States Supreme Court has “consistently focused on employment and promotion requirements that create a discriminatory bar to opportunities. [It] has never read [Title VII] as requiring the focus to be placed instead on the overall number of minority or female applicants actually hired or promoted.” (Id., 457 U.S. at p. 450 [ 73 L.Ed.2d at p. 139 ].) In any event, allowing an employer to avoid judicial scrutiny because the number of minorities actually promoted was too small would allow it to benefit from its own discriminatory prac

11987–1987
Franklin Life Insurance v. State Board of Equalization green
cal · 1965
2 sentences

1967Co. v. State Board of Equalization (1965) 63 Cal.2d 222 [ 45 Cal.Rptr. 869 , 404 P.2d 477 ], the Supreme Court held (adopting a position already taken by the Attorney General in 35 Ops.Cal.Atty.Gen. 182 ) that although the new statute would be unconstitutional if applied to a case where the discrimination contemplated by article XIII, section 14 4/5, subdivision (f)(3), is not present, no constitutional defect exists in any ease which meets both the discriminatory test of the constitutional provision and the comparative test of Insurance Code section 685. ( 63 Cal.2d 222 , 227.) By an amendmen

1967Co. v. State Board of Equalization (1965) 63 Cal.2d 222 [ 45 Cal.Rptr. 869 , 404 P.2d 477 ], the Supreme Court held (adopting a position already taken by the Attorney General in 35 Ops.Cal.Atty.Gen. 182 ) that although the new statute would be unconstitutional if applied to a case where the discrimination contemplated by article XIII, section 14 4/5, subdivision (f)(3), is not present, no constitutional defect exists in any ease which meets both the discriminatory test of the constitutional provision and the comparative test of Insurance Code section 685. ( 63 Cal.2d 222 , 227.) By an amendmen

11967–1967

Where else courts name it

MS 8 (1995–2007) CA 8 (1967–2022) WA 5 (2001–2017) AL 4 (1993–1994) TX 4 (1993–1998) NY 4 (1937–1981) FL 4 (1991–1992) UT 3 (2014–2014) MA 3 (1990–2012) OH 3 (2003–2013) TN 2 (1989–1994) PA 2 (1956–1981) MD 2 (1988–1995)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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