What is the standard of review of a denial of a Batson/Wheeler motion on appeal?

California, United States of America


The following excerpt is from People v. Estrada-Luquin, A156155 (Cal. App. 2020):

"Review of a trial court's denial of a [Batson/Wheeler] motion is deferential, examining only whether substantial evidence supports its conclusions." (People v. Lenix (2008) 44 Cal.4th 602, 613; see People v. Crittenden (1994) 9 Cal.4th 83, 117 [" ' "Because Wheeler motions call upon trial judges' personal observations, we view their rulings with 'considerable deference' on appeal." ' ")

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