Flowers v. Mississippi

Summary

**Flowers v. Mississippi, 139 S. Ct. 2228 (2019)** – The Supreme Court reversed a capital murder conviction, holding that the trial court clearly erred under *Batson v. Kentucky* by finding the State’s peremptory strike of a black prospective juror was not motivated by discriminatory intent. The Court emphasized that a totality-of-circumstances analysis must include the State’s historical pattern of striking black jurors across six trials, disparate questioning of black and white venire members, and side-by-side comparisons of struck and seated jurors. The decision reinforces that even a single racially motivated strike violates equal protection and that appellate courts must consider all relevant evidence, including prior Batson violations and pretextual explanations.

Holdings

1. All of the relevant facts and circumstances taken together establish that the trial court committed clear error in concluding that the State's peremptory strike of black prospective juror Carolyn Wright was not motivated in substantial part by discriminatory intent.

Questions Presented

1. Whether the trial court clearly erred in concluding that the State's peremptory strike of black prospective juror Carolyn Wright was not motivated in substantial part by discriminatory intent, in violation of Batson v. Kentucky.

Disposition

reversed and remanded