State of Tennessee v. Stephen Mobley

John Ballard April 17, 2023

State v. Mobley, No. E2022-00440-CCA-R3-CD (Tenn. Crim. App. Feb. 22, 2023).

A Hamilton County jury convicted the Defendant, Stephen M. Mobley, of two counts of first-degree premeditated murder. In his first appeal, the Defendant contended that the trial court erred when it failed to make requisite findings based on Batson v. Kentucky regarding the State’s use of a peremptory challenge to strike an African-American potential juror during voir dire.

Facts and Procedural History:

  1. The Defendant appealed for a Batson violation, arguing that the prosecution excluded Juror 10, a member of a racial minority, from the jury pool based on race.

  2. The case was remanded for a hearing, where the court found that the Defendant had established a prima facie case of discrimination.

  3. The burden shifted to the State to offer race-neutral explanations for striking Juror 10. The State offered five race-neutral reasons for excluding Juror 10, which included: a. Juror 10's prior jury service and not-guilty verdict in a Connecticut case. b. Juror 10's statement indicating she did not want to be the judge. c. Juror 10's belief that the case could involve being at the wrong place at the wrong time. d. Juror 10's transportation concerns. e. Juror 10's lack of enthusiasm about sequestration.

  4. The Defendant argued that the actual reason for excluding Juror 10 was not race-neutral and that there was no "cure" for the issue, requiring a new trial.

  5. The trial court found the State's explanations for striking Juror 10 to be legitimate, non-pretextual, and not inherently discriminatory. Consequently, the court denied the Defendant's motion for a new trial based on the Batson violation.

  6. The Defendant appealed the judgment.

Issues Raised:

  1. The Defendant asserted that the State did not offer a race-neutral explanation for striking Juror 10 and that the State's reasons were vague, equivocal, inconsistent, and unsupported by the record.

  2. The Defendant contended that the State never offered its “actual” reason for striking Juror 10 but instead offered possible reasons, and that the trial court’s findings cannot salvage the State’s failure to offer a legitimate, non-discriminatory reason for striking Juror 10.

  3. The State countered that the prosecutor offered five race-neutral reasons for striking Juror 10, and the trial court determined that these reasons were sufficient and not pretextual.

  4. The Defendant, in reply, maintained that the State failed to address that the prosecutor never gave his “actual” reason for striking Juror 10 and that the reasons articulated by the State were vague and inconsistent and unsupported by the record.

The court concluded that the trial court did not err when it found that the State did not engage in purposeful discrimination when it struck Juror 10. The Defendant's appeal was denied.