Supreme Court creates a three-step test for racial jury bias in Batson v. Kentucky

The Supreme Court overruled Swain v. Alabama 7-2, establishing that prosecutors may not use peremptory challenges to remove jurors solely on account of race. Justice Lewis Powell wrote the majority opinion, creating a three-step burden-shifting framework: the defendant shows a prima facie pattern; the prosecutor offers a race-neutral explanation; the court rules on pretext. James Batson, a Black man convicted of burglary in Louisville, had watched the prosecutor strike all four Black potential jurors before a jury of twelve whites convicted him.