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Robert Anthony Claytonv.The State

CourtCourt of Appeals of Georgia
Docket No.A16A2147
DecidedFebruary 17, 2017
JudgesCourt of Appeals of Georgia
Tags
CriminalCriminal ProcedureConstitutional LawEqual ProtectionReversalDissentEn Banc
Case Summary

Robert Anthony Clayton challenged the State’s use of a peremptory strike against an African-American juror in his criminal trial. The Court of Appeals had previously remanded for a hearing on the Batson challenge, and the trial court later found that the prosecutor’s explanation was race-neutral. Sitting as a whole court, the Court of Appeals reversed the denial of Clayton’s motion for a new trial. The majority held that the State’s stated reason for striking the juror was not supported by the record and reflected a racial stereotype rather than a genuine race-neutral explanation. The court emphasized that a trial court must evaluate the credibility and consistency of the explanation against the entire record and may not accept a facially neutral reason that is contradicted by comparable treatment of other jurors. The judgments were reversed in the consolidated cases. One judge concurred in the judgment only, and several judges dissented, concluding that the trial court’s finding was not clearly erroneous.

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Robert Anthony Clayton V. The State — The Atlanta Gleaner