Flowers v. Mississippi

Curtis Flowers was tried six times for the 1996 murders of four employees at Tardy Furniture store in Winona, Mississippi. In each trial, prosecutor Doug Evans used peremptory strikes to remove nearly every eligible Black prospective juror. The U.S. Supreme Court reviewed whether this pattern of strikes across multiple trials violated Batson v. Kentucky, which forbids excluding jurors solely on account of race. The Court examined all six trials, focusing on the sixth trial’s jury selection, and found that Evans’s strikes were motivated in substantial part by discriminatory intent. This case highlighted the extreme history of retrials and the State’s persistent removal of Black citizens from jury service.

The U.S. Supreme Court ruled 7-2 in favor of Flowers, holding that the trial court clearly erred in finding that the State’s strikes were not racially motivated. The judgment of the Mississippi Supreme Court was reversed, and the case was remanded for a new trial.

Whether the prosecutor’s peremptory strikes of Black prospective jurors across Curtis Flowers’s six trials, and particularly in his sixth trial, violated the Fourteenth Amendment’s Equal Protection Clause under Batson v. Kentucky by intentionally discriminating on the basis of race.

The decision reinforced Batson’s protections against racial discrimination in jury selection, requiring courts to consider the broader historical pattern of strikes. It sent a strong message to prosecutors about scrutinizing peremptory challenges, significantly impacted capital punishment cases, and advanced efforts to ensure fair racial representation on juries across the United States.