comparative juror analysis (Arizona) · Go Syfert
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comparative juror analysis in Arizona

5 Arizona opinions name it 2 courts 2020–2021 2 in the last five years

The cases below were cited by Arizona 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
State of Arizona v. Efren Medinagreen
ariz · 2013 · cited in 4 Arizona opinions naming this issue, 2020–2021
2 sentences

2021However, courts are not required to employ a comparative analysis when reviewing Batson claims, see Medina, 232 Ariz. at 404– 05 ¶¶ 48–49 (rejecting the argument that a comparative juror analysis is a constitutionally required aspect of Batson review), and this Court “decline[s] to do so when the similarities between peremptorily stricken jurors and those remaining on the panel were not raised at trial,” id. at 405 ¶ 48.

2021However, courts are not required to employ a comparative analysis when reviewing Batson claims, see Medina, 232 Ariz. at 404– 05 ¶¶ 48–49 (rejecting the argument that a comparative juror analysis is a constitutionally required aspect of Batson review), and this Court “decline[s] to do so when the similarities between peremptorily stricken jurors and those remaining on the panel were not raised at trial,” id. at 405 ¶ 48.

24
Miller-El v. Dretkegreen
scotus · 2005 · cited in 1 Arizona opinions naming this issue, 2021–2021
1 sentence

2021Moreover, Porter did not object in the trial court to its purported failure to conduct a comparative juror analysis. ¶21 “Comparing prospective jurors who were struck and not struck can be an important step in determining whether a Batson violation occurred.” Flowers, 139 S. Ct. at 2248 ; see also Miller-El v. Dretke, 545 U.S. 231, 241 (2005).

11
United States v. Tony Alanisgreen
ca9 · 2003 · cited in 1 Arizona opinions naming this issue, 2020–2020
1 sentence

2020Addressing a Batson challenge, You held that a trial court cannot simply deem a race-neutral explanation “plausible,” but must make a “clear record” and “deliberate decision” as to whether there was purposeful discrimination. 382 F.3d at 968 n.2, 969 (quoting United States v. Alanis, 335 F.3d 965, 967 (9th Cir. 2003)). ¶73 Smith’s argument is not persuasive.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (2)

CaseCitedYears
Flowers v. Mississippi green
scotus · 2019
1 sentence

2021Moreover, Porter did not object in the trial court to its purported failure to conduct a comparative juror analysis. ¶21 “Comparing prospective jurors who were struck and not struck can be an important step in determining whether a Batson violation occurred.” Flowers, 139 S. Ct. at 2248 ; see also Miller-El v. Dretke, 545 U.S. 231, 241 (2005).

12021–2021
Snyder v. Louisiana green
scotus · 2008
2 sentences

2020Porter also did not raise a comparative-juror analysis issue regarding Prospective Juror 2 with the superior court, and our supreme court has specifically warned appellate courts from engaging in “a retrospective comparison of jurors based on a cold appellate record . . . when alleged similarities were not raised at trial.” Medina, 232 Ariz. at 404-05 , ¶ 48 (quoting Snyder, 552 U.S. at 483 ).

2020Thus, these arguments do not alter my conclusion. 15 STATE v. PORTER McMurdie, J., dissenting court’s ruling aside, the majority and I part ways on a more significant ground here: its interpretation of Snyder.5 ¶37 In Snyder, the Court found that it could not “presume that the trial judge credited the prosecutor’s assertion” concerning a juror’s nervousness because the trial court upheld the strikes without explanation and that the prosecutor’s second proffered reason failed to survive scrutiny “even under the high deferential standard of review that is applicable here.” Snyder, 552 U.S. at 47

12020–2020

Where else courts name it

CA 69 (1995–2025) TX 11 (2008–2021) IL 10 (2003–2024) NC 8 (2020–2025) ID 7 (2014–2023) AZ 5 (2020–2021) NV 3 (2011–2022) CO 3 (2012–2017) OR 2 (2019–2022) RI 2 (2007–2018) MS 2 (2022–2024) IA 2 (2019–2019) IN 2 (2012–2017)

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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