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Scott v. State, 280 Ga. 466, 629 S.E.2d 211 (April 25, 2006). Race-neutral reasons for strikes: With regard to the second potential juror, the State argued that it struck her from the jury because she was either non-responsive to the State’s questions, or she would say one thing and then immediately contradict herself. In addition, the second juror also stated that she felt that a criminal offense which required a two-year jail term was a ‘small thing.’ The State argued that it struck her from the jury because this answer ‘reflects a callousness either for the law or the sentence or both.’ In addition, many of her answers to questions simply could not be comprehended. In both of these cases, the State provided a concrete race- neutral reason for striking the jurors in question.” Taylor v. State, 279 Ga. 706, 620 S.E.2d 363 (October 3, 2005). Acceptable race-neutral explanations for strikes: limited educational and work experience; juror “seemed odd,” and had limited education and work history ; juror “was unemployed and also demonstrated a lack of seriousness for the judicial process.” Benham concurs specially to urge trial judges to develop a record where jurors are struck for “seeming odd” or not taking the process seriously. Reed v. State, 279 Ga. 81, 610 S.E.2d 35 (March 7, 2005). In murder trial: “The State explained that it struck the … venireman at issue because he was not a gun owner, his mannerisms were strange, and because he appeared to be less attentive than some of the other prospective jurors .” Accord, Washington v. State , 310 Ga.App. 775, 714 S.E.2d 364 (July 13, 2011) (inattentiveness of potential juror is a race-neutral reason). Rakestrau v. State, 278 Ga. 872, 608 S.E.2d 216 (January 24, 2005). Fact that State used all four of its strikes against African-Americans, where panel was evenly divided between whites and African-Americans, “made a prima facie case of discrimination.” Strikes were all race-neutral, however, based on juror’s “observed camaraderie with a fellow prospective juror who had previously served as a witness in an unrelated murder trial in which both prosecutors had participated;” juror was “inattentive during voir dire;” juror was primary caregiver for her disabled child and fell asleep during voir dire. Accord, Heard v. State , 295 Ga. 559, 761 S.E.2d 314 (July 11, 2014) (“observed camaraderie” talking to another juror “particularly about police officers.”). Barrow v. State, 269 Ga.App. 635, 605 S.E.2d 67 (September 16, 2004). Fact that “the potential juror failed to return to the courtroom after a break” was an acceptable race-neutral reason for strike of only black venireman. McKee v. State, 277 Ga. 577, 591 S.E.2d 814 (January 12, 2004). Trial court could find that defense “was motivated by discriminatory intent” in striking juror who “was the victim of a previous crime who could not remember the details of the crime” while not striking other crime victims. Contrary to counsel’s explanation, the inability to remember the details did not indicate that “she could not pay proper attention to the trial.” Reedman v. State, 265 Ga.App. 162, 593 S.E.2d 46 (December 19, 2003). “[T]he juror was extremely nervous, confused, and had problems following the voir dire questions. ” George v. State, 263 Ga.App. 541, 588 S.E.2d 312 (October 3, 2003). Finds a number of Batson violations where prosecutor struck four of five available black men on the panel, based on the totality of circumstances: evidence contradicted prosecutor’s claim about juror’s “unstable job history,” thus rendering it “so implausible and fantastic as to render the explanation pretextual;” record did not support “prosecutor’s bare assertions about” the juror smiling at defendant and frowning at prosecutor, and prosecutor made no effort to make inquiry about this behavior; struck black male for wearing earring, but allowed white male who wore earring, and did not explain how this “related to the case at hand or how it would render him unable to be a fair and impartial juror;” counsel’s “level of comfort or rapport with the juror is too vague, subjective, non-specific and non-case-related to meet the requirements of Batson ;” “[t]he mere fact that the juror was not working because he planned to go on a family vacation prior to returning to college is, under all the circumstances, such an implausible basis for striking the juror that it rises to the level of being pretextual;” and striking one juror to reach other preferred jurors can be race-neutral, but isn’t in this case where the preferred jurors are not the same race/gender and in light of the other rejected reasons. Trigger v. State, 275 Ga. 512, 570 S.E.2d 323 (September 30, 2002). “Inattentiveness during voir dire, sleeping through voir dire, and having a relative with a pending charge in a criminal case are race-neutral reasons for striking jurors.” Accord, Kimble v. State , 301 Ga.App. 237, 687 S.E.2d 242 (November 20, 2009) (sleeping juror); Washington v. State , 310 Ga.App. 775, 714 S.E.2d 364 (July 13, 2011) (inattentive juror).

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