New York Court of Appeals
The People of the State of New York, Respondent v. Daniel Payne, Appellant; the People of the State of New York…
May 7, 199688 N.Y.2d 172
Summary
The New York Court of Appeals affirmed the trial court’s finding of purposeful discrimination in People v. Payne, but modified and remanded the orders in People v. Jones and People v. Lowery because the trial courts failed to follow the proper three‑step Batson protocol. The Court clarified that a facially race‑neutral explanation satisfies the step‑two burden, and that the People retain the ultimate burden of proving pretext at step three.