Hayes v. State

Defendant was tried on three counts of armed robbery and three counts of false imprisonment with a weapon or firearm. At issue was the misapplication of the trial court and the First District of the procedure the court set forth in Melbourne v. State for eliminating discrimination during the exercise of peremptory challenges. In this case, the trial court erred in denying defense counsel's peremptory challenge to a female juror, notwithstanding the undisputed gender-neutral reason counsel proffered. The trial court mistakenly assessed defense counsel's reason as if it were assessing a challenge for cause and failed to perform the critical third step of the Melbourne procedure, which required an assessment of the genuineness of counsel's proffered reasons for the strike. Further, the trial court erroneously relieved the State of its burden to establish that the reason for the challenge was pretextual. The court concluded that the First District district perpetuated these errors and quashed the decision of the First District.