People v. Bradshaw

Illinois Appellate Court
Criminal Court
Jury Selection
Citation
Case Number: 
2020 IL App (3d) 180027
Decision Date: 
Tuesday, December 8, 2020
District: 
3d Dist.
Division/County: 
Peoria Co.
Holding: 
Reversed and remanded.
Justice: 
LYTTON

Defendant was convicted, after jury trial, of unlawful possession with intent to deliver a controlled substance. Court erred in finding that State's explanation for striking an African-American potential juror was race-neutral and valid. State's explanation that juror was dismissed for personality reasons lacked the clarity, legitimacy, and specificity required by U.S. Supreme Court's 1986 Kentucky v. Batson decision. State's explanation that he was also dismissed because of his "criminal contacts", without any showing that he had been charged or convicted of any crime, was insufficient to rebut Defendant's prima facie showing that it excluded him based on race. (HOLDRIDGE and McDADE, concurring.)