State v. Leron Porter

Summary

The court vacated the defendant's convictions because the trial justice did not meaningfully perform the third step of the required equal-protection analysis for the prosecutor's peremptory strike of the sole African-American venireperson. Although the prosecutor articulated facially race-neutral reasons, the trial justice did not adequately assess their credibility, pretext, or the surrounding circumstances on the record. The court held that a completed jury-selection violation of this kind is structural error requiring a new trial.