Can a defense counsel challenge the only African-American juror at a civil trial?

MultiRegion, United States of America

The following excerpt is from Crenshaw v. Herbert, No. 09-0348-pr (2nd Cir. 2011):

That defense counsel challenged the only African-American juror does not automatically support an inference of discriminatory intent. Cousin v. Bennett, 511 F.3d 334, 338 (2d Cir. 2008). Here, the juror's background supports a logical race-neutral motivation for the challenge. It is entirely plausible that a lawyer defending a corrections officer from a prisoner's lawsuit would be reluctant to seat a juror, of any race, who had herself been a plaintiff and who was employed in a role involving advocacy on behalf of prisoners.

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