HCBA Lawyer Magazine Vol. 30, No. 2 | Page 26

whosE linE is it anyway: prEsErving Batson oBJEctions Appellate Practice Section Chairs:­Joe­Eagleton­–­Brannock­&­Humphries­and­Chance­Lyman­–­Buchanan­Ingersoll­&­Rooney the burden of persuasion never leaves the opponent F lorida appellate courts have long strived to assist trial judges and litigators in “conforming with article I, section 16, Florida Constitution, and the equal protection provisions of our state and federal constitutions,” with the laudable goal of eliminating “discrimination in the exercise of peremptory challenges.” 1 In Melbourne v. State, the supreme court refined the procedure for Batson 2 objections, with the proviso that the right to an impartial jury “is best safeguarded not by an arcane maze of reversible error traps, but by reason and common sense.” 3 In Step 1, the opponent of the peremptory challenge must object, show the venireperson belongs to a protected class, request the court ask the proponent its reason for the challenge. 4 In Step 2, the proponent must provide a non-discriminatory explanation. In Step 3, the court must determine whether that explanation is genuine; if it is, the strike will be sustained. Critically, the burden of persuasion never leaves the opponent to prove purposeful discrimination. The opponent must renew the objection before the jury is sworn. 5 Twenty years later, the Second District provided a comprehensive roadmap for preserving Melbourne issues. 6 Addressing Step 3, the 24 to prove purposeful discrimination. Second District concluded that trial courts do not have an “automatic burden” to perform a genuineness analysis every time an opponent objects and the proponent provides a facially neutral explanation. 7 To preserve the issue, the opponent must expressly make a claim of pretext, proffer circumstances supporting the claim, and object to deficiencies in the procedure. Although it is “unquestionably the better practice” for the trial court to ask the opponent whether he or she wishes to raise a genuineness challenge and what circumstances support the claim, the Second District saw no reason to reverse for the “drastic” new-trial remedy when the trial court omits Step 3 without objection and the opponent fails to ensure the record is adequate for review. 8 A plurality of the Supreme Court approved the Second District’s decision but not its analysis. 9 The plurality explained that a trial court “has a duty to perform the correct legal analysis independent of trial counsel’s duty.” 10 Below, the trial judge performed this duty by requesting a response from defense counsel following the State’s purported non-discriminatory explanation and before ruling on genuineness. The plurality found the issue preserved but determined the trial court did not err in overruling the objection in light of defense counsel’s failure to respond to the State’s explanation. 11 Despite the disapproval of the Second District’s preservation analysis by a plurality of the supreme court, the takeaway is clear: litigants should ensure the trial court proceeds through each step of the Melbourne procedure and confirm the record contains the basis of the objection for appellate review. n Melbourne v. State, 679 So. 2d 759, 764 (Fla. 1996). 2 Batson v. Kentucky, 476 U.S. 79 (1986). 3 Melbourne, 679 So. 2d at 765. 4 Id. at 764. 5 Id. at 765. 6 Spencer v. State, 196 So. 3d 400 (Fla. 2d DCA 2016). 7 Id. at 401. 8 Id. at 407. 9 Spencer v. State, 238 So. 3d 708, 711 (Fla. 2018). 10 Id. at 716. 11 Id. at 717. 1 Author: Chance Lyman - Buchanan Ingersoll & Rooney PC NOV - DEC 2019 | HCBA LAWYER