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Littlejohn v. State, 320 Ga.App. 197, 739 S.E.2d 682 (March 8, 2013). Burglary and related convictions affirmed; trial court properly denied defendant’s Batson challenges. Strike based on juror’s ponytail was race-neutral. “Since the growing of long, unkempt hair is not a characteristic that is peculiar to any race, the trial court was authorized to find that the prosecutor had offered a race-neutral explanation for its strike. See Purkett v. Elem, 514 U.S. 765, 769 (115 S.Ct. 1769, 131 L.Ed.2d 834) (1995) (ruling that a prosecutor's explanation that he struck a juror because he had long, curly, and unkempt hair was sufficient to survive the second prong of the Batson analysis).” Bell v. State, 306 Ga.App. 853, 703 S.E.2d 680 (October 26, 2010). Burglary conviction affirmed; strike of juror was race-neutral where “based on the fact that the prosecutor had difficulty understanding the jurors in question , and was therefore concerned about their ability to articulate their positions or perhaps to reason. With respect to these jurors, Bell first argues that the State's assertion that ‘it could not understand certain “ethnic” manners of speech [is] racially suspect on its face.’ There is, however, no evidence in the record that the prosecution could not understand these jurors because of their ‘manner of speech,’ ethnic or otherwise. Indeed, Bell's argument in this regard appears to be based on the same presumptions and/or stereotypes that Batson is designed to protect against.” Chandler v. State, 281 Ga. 712, 642 S.E.2d 646 (March 19, 2007). Race-neutral reasons: State could strike juror with a pierced eyebrow. Young v. State, 272 Ga.App. 304, 612 S.E.2d 118 (March 21, 2005). Juror “was diabetic, did not appear to be in total command of his faculties, believed in witchcraft, was difficult to understand, and did not appear to understand questions asked of him.” 20. STRIKES BASED ON POLITICAL, MORAL, RELIGIOUS BELIEFS/ATTITUDES Woodall v. State, 294 Ga. 624, 754 S.E.2d 335 (January 27, 2014). In capital murder prosecution, no Batson violation where State struck juror who said “all life is precious” when questioned about her attitude toward the death penalty. Tyre v. State, 323 Ga.App. 37, 747 S.E.2d 106 (July 15, 2013). Rape and related convictions affirmed; strike was race neutral where juror’s “bag had the phrase ‘Jesus is the final answer’ written on it, which indicated that she could be inclined to avoid judging others. Our Supreme Court has held that a strong religious point of view is a valid race-neutral reason for striking a juror. See Berry v. State, 268 Ga. 437, 439(2) (490 S.E.2d 389) (1997).” 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 exercised its peremptory strike against him based on a legitimate concern that his religious beliefs affected his views on judgment and punishment and that, in turn, those beliefs would affect his ability to follow the court's instructions should the two conflict.” Casts doubt on defendant’s argument “that Batson extends to the State's use of peremptory strikes against individuals based on their religious affiliation, and he asserts that the State's other reasons for its strikes were pretextual. … Bryant has provided no authority for his argument that Batson extends to the use of peremptory strikes against individuals based on their religious affiliation.” Hunt v. State, 288 Ga. 794, 708 S.E.2d 357 (March 18, 2011). Malice murder and related convictions affirmed; asserted reasons for strikes were race-neutral: juror had a cousin in prison; she had a relative who was the victim of a murder which “involved a drug deal that went bad,” which was the scenario posited by the defense; and “she considered herself a liberal.” Reid v. State, 298 Ga.App. 889, 681 S.E.2d 671 (July 10, 2009). No clear error where trial court disallowed defense strike: defense rejected a white juror on grounds that she “believed that the person likely responsible for the rape and murder of her friend was not sufficiently punished,” but failed to strike black juror who “agreed that ‘people who are convicted of drugs offenses [like the one at issue here] should be incarcerated and not be given probation.’” LeMon v. State, 290 Ga.App. 527, 660 S.E.2d 11 (March 3, 2008). Strikes were race-neutral: “The prosecuting attorney testified that he struck the first prospective juror because 1. she had children and grandchildren close in age to LeMon and because her responses to questions in voir dire suggested that she was biased toward him. 2. The second prospective juror was struck based on her belief that drinking alcohol was morally wrong, suggesting that she might be prejudiced against the victims , who had been drinking at the party, and because her uncle had been convicted of armed robbery.
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