race-neutral reason challenge (Illinois) · Go Syfert
← Illinois issues

race-neutral reason challenge in Illinois

9 Illinois opinions name it 1 courts 2000–2025 5 in the last five years

The cases below were cited by Illinois 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 (3)

CaseFollowedCited
People v. Davisgreen
ill · 2008 · cited in 4 Illinois opinions naming this issue, 2022–2025
2 sentences

2025As the Supreme Court acknowledged in Hernandez, the credibility of the attorney’s explanation ‘goes to the heart of the equal protection analysis, and once that has been settled, there seems nothing left to review.’ (Emphasis added.) Hernandez, 500 U.S. at 367 .” Rivera, 221 Ill. 2d at 502 . ¶ 98 Our supreme court has further recognized that “a race-neutral reason for a challenge often invokes a juror’s demeanor (e.g., nervousness, inattention, the way words are emphasized to express differing meanings), making the trial court’s firsthand observations of crucial importance.” Davis, 231 Ill. 2d

2022Where the race-neutral reason for a challenge invokes a juror’s demeanor, such as hesitancy, the trial court’s firsthand observations are “of crucial importance.” Davis, 231 Ill. 2d at 363-64 .

24
Snyder v. Louisianagreen
scotus · 2008 · cited in 2 Illinois opinions naming this issue, 2025–2025
2 sentences

2025Hence, “the -12- trial court must evaluate not only whether the prosecutor’s demeanor belies discriminatory intent, but also whether the juror’s demeanor can credibly be said to have exhibited the basis for the strike attributed to the juror by the prosecutor.” Id. at 364 (citing Snyder, 552 U.S. at 477 ).

2025“In such situations, the trial court must evaluate not only whether the [striking attorney’s] demeanor belies discriminatory intent, but also whether the juror’s demeanor can credibly be said to have exhibited the basis for the strike attributed to the juror by the [striking attorney].” Id. at 364 (citing Snyder v. Louisiana, 552 U.S. 472, 477 (2008)). - 43 - ¶ 99 Because the trial court’s firsthand observations of these matters are of such crucial importance to the third-step determination, “a reviewing court must defer to the trial court absent ‘exceptional circumstances.’ ” People v. Crawfo

12
People v. Crawfordgreen
illappct · 2014 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025“In such situations, the trial court must evaluate not only whether the [striking attorney’s] demeanor belies discriminatory intent, but also whether the juror’s demeanor can credibly be said to have exhibited the basis for the strike attributed to the juror by the [striking attorney].” Id. at 364 (citing Snyder v. Louisiana, 552 U.S. 472, 477 (2008)). - 43 - ¶ 99 Because the trial court’s firsthand observations of these matters are of such crucial importance to the third-step determination, “a reviewing court must defer to the trial court absent ‘exceptional circumstances.’ ” People v. Crawfo

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (4)

CaseCitedYears
Batson v. Kentucky green
scotus · 1986
2 sentences

2007Batson, 476 U.S. at 87 , 90 L.

2007Batson, 476 U.S. at 87 , 90 L.

22007–2007
Purkett v. Elem green
scotus · 1995
2 sentences

2000Ed. 2d at 839 , 115 S. Ct. at 1771 ), the State nevertheless must articulate a race-neutral reason for its challenge at step two, a burden that should not be eliminated.

2000Although under the current Batson requirements as articulated by the Supreme Court in Purkett , the explanation tendered by the State at stage two need not be "persuasive or even plausible" ( Purkett , 514 U.S. at 767-68 , 115 S.Ct. at 1771 ) the State nevertheless must articulate a race-neutral reason for its challenge at step two, a burden that should not be eliminated.

22000–2000
People v. Rivera green
ill · 2006
1 sentence

2025As the Supreme Court acknowledged in Hernandez, the credibility of the attorney’s explanation ‘goes to the heart of the equal protection analysis, and once that has been settled, there seems nothing left to review.’ (Emphasis added.) Hernandez, 500 U.S. at 367 .” Rivera, 221 Ill. 2d at 502 . ¶ 98 Our supreme court has further recognized that “a race-neutral reason for a challenge often invokes a juror’s demeanor (e.g., nervousness, inattention, the way words are emphasized to express differing meanings), making the trial court’s firsthand observations of crucial importance.” Davis, 231 Ill. 2d

12025–2025
Hernandez v. New York green
scotus · 1991
2 sentences

2025“In such situations, the trial court must evaluate not only whether the [striking attorney’s] demeanor belies discriminatory intent, but also whether the juror’s demeanor can credibly be said to have exhibited the basis for the strike attributed to the juror by the [striking attorney].” Id. at 364 (citing Snyder v. Louisiana, 552 U.S. 472, 477 (2008)). - 43 - ¶ 99 Because the trial court’s firsthand observations of these matters are of such crucial importance to the third-step determination, “a reviewing court must defer to the trial court absent ‘exceptional circumstances.’ ” People v. Crawfo

2025As the Supreme Court acknowledged in Hernandez, the credibility of the attorney’s explanation ‘goes to the heart of the equal protection analysis, and once that has been settled, there seems nothing left to review.’ (Emphasis added.) Hernandez, 500 U.S. at 367 .” Rivera, 221 Ill. 2d at 502 . ¶ 98 Our supreme court has further recognized that “a race-neutral reason for a challenge often invokes a juror’s demeanor (e.g., nervousness, inattention, the way words are emphasized to express differing meanings), making the trial court’s firsthand observations of crucial importance.” Davis, 231 Ill. 2d

12025–2025

Where else courts name it

TN 24 (1992–2021) TX 11 (1997–2023) MN 10 (1998–2017) IL 9 (2000–2025) NY 8 (1993–2022) FL 7 (1998–2006) MA 5 (1991–2022) MS 4 (1994–2002) CA 2 (2013–2015)

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.

← Caselaw search · G Cite Topics · Brief Check