Larry Yarborough, Appellant v. the State of Texas

Summary

The Texas Court of Criminal Appeals reversed the Court of Appeals and remanded for further review, holding that an unchallenged prosecutor’s statement about a venire member’s demeanor is sufficient evidence to support a trial court’s finding that a peremptory challenge is race‑neutral in a Batson hearing, and that appellate review of such findings should be on a clearly erroneous (deferential) standard. The Court also rejected the appellate rule requiring independent corroboration of the prosecutor’s demeanor description. Justice Baird dissented, arguing that independent, objectively verifiable evidence is required, while Judges Mansfield and Overstreet concurred, agreeing with the reversal but offering additional reasoning on the standard of review and the impact of Purkett.