California, United States of America
The following excerpt is from People v. Gomez, F075252 (Cal. App. 2020):
As noted by the court, the prosecutor's motion was not based on defense counsel's decision to challenge one or two Caucasian jurors, a situation which rarely suggests a pattern of impermissible exclusion. (People v. Bonilla, supra, 41 Cal.4th at p. 343.) The court properly found counsel had used a "disproportionate number of his peremptories" against a cognizable group and that was sufficient to find a prima facie case. (Rhoades, supra, 8 Cal.5th at pp. 423-424.)
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