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Askew v. State, 254 Ga.App. 137, 564 S.E.2d 720 (February 15, 2002). Acceptable race-neutral reasons for strikes where: Juror did not give honest answers to questions regarding prior arrests. Accord, Wilkins v. State , 291 Ga. 483, 731 S.E.2d 346 (September 10, 2012). 13. STRIKES BASED ON JUROR DISABILITY Livingston v. State, 271 Ga. 714, 524 S.E.2d 222 (November 22, 1999). Defendant’s convictions for murder and related offenses affirmed; no Batson violation where prospective juror was struck based on hearing impairment; “the State was concerned that her physical location in the jury box would enhance such impairment. The State then offered that it also struck a Caucasian venireperson because of hearing impairment.” 14. STRIKES BASED ON JUROR HARDSHIP Bryant v. State, 288 Ga. 876, 708 S.E.2d 362 (March 18, 2011). Capital murder conviction affirmed (but sentence reversed); State’s strike was race-neutral. “The State explained that it excused Juror Sparks for the following reasons: the trial court had to wait on him twice, as he was 30 to 45 minutes late for panel voir dire and at least an hour late on the day that the jury was struck; he told the court that he was the sole support for his five children and his ex-wife, that jury service would ‘buckle his knees’ financially, and that his utilities would be turned off if he had to serve;[fn] he asked the court what would happen if he wanted to impose a sentence of life with parole and the remaining jurors opted for life without parole, and he said that the death penalty would be a ‘last resort’ option for him; and he had children in the same age range as Bryant.” Stovall v. State, 287 Ga. 415, 696 S.E.2d 633 (June 28, 2010). “[T]he venire member's concerns about the hardship of jury service on his employment” constituted a race-neutral reason for strike, citing Flanders v. State, 279 Ga. 35(2) (609 S.E.2d 346) (2005). Flanders v. State, 279 Ga. 35, 609 S.E.2d 346 (February 21, 2005). No Batson violation: Juror’s “recollection abilities were called into question when he could not remember on what type of jury he had previously served; his service would create an extreme hardship because he was required to care for a dependent aunt; and he would find the evidence too offensive .” 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 was primary caregiver for her disabled child and fell asleep during voir dire. McKee v. State, 277 Ga. 577, 591 S.E.2d 814 (January 12, 2004). Fact “that difficulties associated with childcare arrangements would create a hardship for” juror was “a legitimate, race-neutral basis for the exercise of a jury strike.” Shell v. State, 264 Ga.App. 547, 591 S.E.2d 450 (December 4, 2003). Strike because juror was “moving out of state and was scheduled to start a job in her new city in the next week” and might therefore be “‘distracted’ or ‘preoccupied’” is not pretextual. King v. State, 273 Ga. 258, 539 S.E.2d 783 (November 30, 2000). Malice murder and related convictions affirmed. Strikes were race- and gender-neutral: Juror “was a single mother who would be financially burdened by jury service.” Scott v. State, 240 Ga.App. 50, 522 S.E.2d 535 (September 14, 1999). State strikes were race-neutral: “Juror 1 was struck for health reasons and because a family member had a prior conviction. See Slade v. State, 270 Ga. 305, 509 S.E.2d 618 (1998). Juror 25 was struck because she lived in what is apparently the worst drug crime area in Columbus. The trial court noted that a juror from that area may well be ‘scared to go home having convicted somebody of a drug offense.’ See Smith v. State, 264 Ga. 449, 454, 448 S.E.2d 179 (1994); Sorrells v. State, 218 Ga.App. 413, 414, 461 S.E.2d 904 (1995).” Snyder v. Louisiana, 552 U.S. 472, 128 S.Ct. 1203, 170 L.Ed.2d 175 (March 19, 2008). Louisiana courts erred in ruling that prosecutor’s peremptory strike didn’t violate Batson . In defendant’s capital murder trial, prosecutor used peremptory strikes to eliminate all five black jurors who were qualified. Prosecutor explained the strike of juror Brooks on the basis of nervousness, and because juror expressed concern at missing his student teaching assignment. Nervousness: trial court’s determinations regarding demeanor are “given much deference,” but here, “the record does not show that the trial judge actually made a determination concerning Mr. Brooks’ demeanor. The trial judge was given two explanations for