Apr. 4, 2022 – People v. Salinas (2nd Dist., Div. 5, B307985)

Where the prosecution exercised five peremptory challenges to strike Black women from the jury, the Court of Appeal holds that the fifth challenge violated Batson and Wheeler. In reaching this holding, the appellate court determines that the deference ordinarily given to a trial court’s evaluation of a prosecutor’s stated nondiscriminatory justification for striking a juror is unwarranted here, “because the trial court did not make a reasoned effort . . . to evaluate the nondiscriminatory justification the prosecutor offered.”