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Knight v. State
Citations: 559 So. 2d 327; 1990 WL 39854Docket: 89-1026
Court: District Court of Appeal of Florida; April 3, 1990; Florida; State Appellate Court
Robert Knight appeals his conviction and sentence for burglary of an occupied structure, arguing that his jury selection violated his rights under Article I, Section 16 of the Florida Constitution, as interpreted in State v. Neil. Knight, classified as a habitual violent felony offender due to multiple prior convictions, contends the trial court erred by not sustaining his objections to the prosecutor's peremptory challenges, which excused several black potential jurors. The court acknowledges the broad discretion of trial courts in such rulings and finds no error in Knight's classification and sentencing. Although four out of six jurors were black, Knight claims improper bias in the prosecutor's use of challenges against other black jurors. The Neil and Slappy cases mandate that a defendant must show a strong likelihood of racial bias in jury selection, shifting the burden to the prosecution to provide valid nonracial reasons for such challenges. During jury selection, the prosecutor used five peremptory challenges, four against black jurors. The trial court did not find sufficient evidence of racial bias to support Knight's claim but noted the prosecutor voluntarily provided reasons for each challenge. The court found three of the reasons valid: one juror had a hearing issue, another had a felony record, and the third was evasive in responses. However, the justification for challenging Miss Bellamy, described as a single mother with a low-income job, was deemed less persuasive. Ultimately, the court affirms Knight's conviction and sentencing. A juror's occupation can justify a peremptory challenge, but it must relate to the case in a Slappy inquiry. In this instance, the prosecutor's challenge of Miss Bellamy, a cook, lacked a clear connection to a burglary case. Her marital status and number of children similarly held no relevance to potential bias. The argument that homeowners might be more inclined to convict than renters was undermined by the presence of other renting jurors. The prosecutor failed to present special circumstances that could justify the challenge related to her status as a parent. The trial court's assessment of the challenge must consider the overall context and credibility of reasons provided, as emphasized in both Slappy and Reed opinions. The trial court found valid reasons for three out of four challenges and noted that four of six jurors were black, undermining claims of racial bias. Although concerns were raised about Miss Bellamy's challenge, the absence of reversible errors in the overall jury selection process led to the conclusion that the trial court acted appropriately. Additionally, the classification and sentencing of the appellant as a habitual violent felony offender under Section 775.084 was affirmed, given his significant prior criminal record. Other constitutional challenges to this classification were deemed without merit. The judgment and sentence were upheld.