People v. Bell
40 Cal. 4th 582, 151 P.3d 292, 54 Cal. Rptr. 3d 453 (2007)
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Rule of Law:
To establish a prima facie case of purposeful discrimination in jury selection under Batson v. Kentucky, a defendant must show that the totality of relevant facts gives rise to an inference of discriminatory purpose; the dismissal of a small number of members of a cognizable group, without more, is generally insufficient to meet this burden.
Facts:
- Steven M. Bell lived at the San Diego home of his girlfriend, Deborah Mitchell, along with her 11-year-old son, Joey Anderson.
- On the morning of June 4, 1992, Bell obtained a $111 assistance check, cashed it, and used the money to buy and smoke crack cocaine.
- After running out of money that afternoon, Bell returned to Mitchell's house with the plan to steal items to sell for more drugs.
- Upon entering, Bell unexpectedly found Joey at home watching television in his mother's bedroom.
- Bell went to the kitchen, retrieved a knife, returned to the bedroom, and repeatedly stabbed Joey, then stomped on his head.
- After killing Joey, Bell took a television and a boom box from the home, placed them in a shopping cart, and left.
- Bell sold the stolen items and used the proceeds to buy and smoke more crack cocaine.
- The next morning, Bell approached a police officer with a newspaper article about the killing, identified himself, and was subsequently taken in for questioning where he eventually confessed.
Procedural Posture:
- Steven M. Bell was charged by information in a California trial court with murder, robbery, and burglary.
- On Bell's motion, the trial court dismissed the burglary charge and the related burglary-murder special-circumstance allegation before trial.
- During jury selection, defense counsel made three separate motions under People v. Wheeler and Batson v. Kentucky, alleging the prosecutor used peremptory challenges to discriminate against African-American women, Filipino-Americans, and lesbians.
- The trial court denied all three motions, finding that the defense had not established a prima facie case of group bias.
- On November 22, 1993, a jury found Bell guilty of first degree murder with a robbery-murder special circumstance.
- On December 17, 1993, the jury returned a verdict of death.
- The trial court denied Bell's motion for a new trial, and on March 7, 1994, sentenced him to death, triggering an automatic appeal to the Supreme Court of California.
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Issue:
Does a prosecutor's use of peremptory challenges to strike two of three African-American women, two Filipino-American men, and two prospective jurors presumed to be lesbians, without other supporting evidence, give rise to an inference of discriminatory purpose sufficient to establish a prima facie case under Batson v. Kentucky?
Opinions:
Majority - Werdegar, J.
No, the prosecutor's use of peremptory challenges does not give rise to an inference of discriminatory purpose. To establish a prima facie case of discrimination, the defendant must show that the totality of relevant circumstances creates such an inference. Here, the number of challenged jurors from each cognizable group was too small by itself to suggest a pattern of impermissible exclusion. The defense failed to present other relevant circumstances, such as desultory questioning of the challenged jurors, their heterogeneity in all respects other than group membership, or the defendant's membership in the excluded group. Because the defense did not meet its initial burden of raising an inference of discrimination, the trial court was correct in not requiring the prosecutor to provide race-neutral reasons for the strikes, and comparative juror analysis is inappropriate on appeal.
Analysis:
This decision clarifies the evidentiary threshold for establishing a prima facie case in a Batson/Wheeler motion, reinforcing that numerical evidence alone, especially with small sample sizes, is rarely sufficient. It underscores that a defendant must present a comprehensive picture based on the totality of circumstances to shift the burden to the prosecution. The ruling also solidifies the principle that appellate courts should not conduct a comparative juror analysis for the first time on appeal when a prima facie case was not found at trial, as there are no proffered neutral reasons from the prosecutor to evaluate or compare.
