What is the test for making a "prima facie" showing that jurors were being excluded on the basis of racial or group identity?

California, United States of America


The following excerpt is from People v. Huerta, F060404, Super. Ct. No. VCF215605A (Cal. App. 2012):

This case concerns the first step in the procedure: whether appellant made a "prima facie showing that jurors [were] being excluded on the basis of racial or group identity. [Citations.] To establish a prima facie case, the defendant should first make as complete a record as possible. [Citations.] Second, the defendant must establish that the persons excluded are members of a cognizable group. [Citations.] Third, the defendant must show a ... reasonable inference that such persons are being challenged because of their group association. [Citations.]" (People v. Farnam, supra, 28 Cal.4th at p. 135.) In

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