Rashawn Dyrone Price, Jr., petitioner, Appellant,
The holding in the court’s own words
Because we conclude that the district court acted within its discretion in denying appellant’s petition for postconviction relief, we affirm. For the same reasons as expressed below concerning our analysis of Pendleton, we conclude that Price’s reliance on Seaver is unconvincing. We therefore conclude that the district court acted within its discretion in reviewing its decision to deny Price’s Batson challenge.
Quoted verbatim from the opinion — no paraphrase, nothing generated. Not yet human-reviewed. How we find the holding.
Authorities cited
Identified automatically; this list may not be exhaustive.
- State v. Harvey 932 N.W.2d 792
- Scruggs v. State 484 N.W.2d 21
- State Ex Rel. Gray v. Tahash 156 N.W.2d 228
- Andersen v. State 913 N.W.2d 417
- Ries v. State 920 N.W.2d 620
- Thomas Daniel Rhodes v. State of Minnesota, A13-560 875 N.W.2d 779
- 963 N.W.2d 205 not in our corpus
- State of Minnesota v. Maureen Ndidiamaka Onyelobi 879 N.W.2d 334
- State v. Rivers 787 N.W.2d 206
- State v. Pendleton 725 N.W.2d 717
- State v. Seaver 820 N.W.2d 627
Opinion text
This opinion is nonprecedential except as provided by
Minn. R. Civ. App. P. 136.01, subd. 1(c).
STATE OF MINNESOTA
IN COURT OF APPEALS
A25-0871
Rashawn Dyrone Price, Jr., petitioner,
Appellant,
vs.
State of Minnesota,
Respondent.
Filed February 9, 2026
Affirmed
Ede, Judge
Hennepin County District Court
File No. 27-CR-23-8449
Cathryn Middlebrook, Chief Appellate Public Defender, Hannah B. Laub, Assistant Public
Defender, St. Paul, Minnesota (for appellant)
Keith Ellison, Attorney General, St. Paul, Minnesota; and
Mitchell S. Sell, Robbinsdale City Attorney, Eckberg Lammers, Stillwater, Minnesota (for
respondent)
Considered and decided by Johnson, Presiding Judge; Ede, Judge; and Jesson,
Judge.∗
∗ Retired judge of the Minnesota Court of Appeals, serving by appointment pursuant to
Minn. Const. art. VI, § 10.
2
NONPRECEDENTIAL OPINION
EDE, Judge
After a jury trial, appellant was convicted of having an alcohol concentration of 0.08
or more within two hours of operating a motor vehicle. Appellant did not file a direct appeal
of his conviction and sentence but later petitioned for postconviction relief, seeking a new
trial and asserting that his right to equal protection under the United States Constitution
was violated when the district court denied his challenge to respondent’s exercise of a
peremptory strike of a potential juror during selection. In this appeal from the district
court’s order summarily denying his postconviction petition, appellant argues that the
district court abused its discretion because (1) the court applied deferential review to its
decision to deny appellant’s challenge to respondent’s peremptory strike and
(2) respondent’s peremptory strike was motivated by racial discrimination and
respondent’s proffered explanation for removing the potential juror was pretextual.
Because we conclude that the district court acted within its discretion in denying
appellant’s petition for postconviction relief, we affirm.
FACTS
Respondent State of Minnesota charged appellant Rashawn Dyrone Price Jr. with
operating a motor vehicle while under the influence of alcohol, in violation of Minnesota
Statutes section 169A.20, subdivision 1(1) (2022), and having an alcohol concentration of
0.08 or more within two hours of operating a motor vehicle, in violation of Minnesota
3
Statutes section 169A.20, subdivision 1(5) (2022). 1 The matter proceeded to a jury trial
over three days in November 2023, after which Price was convicted of having an alcohol
concentration of 0.08 or more within two hours of operating a motor vehicle and acquitted
of operating a motor vehicle while under the influence of alcohol. The district court stayed
execution of a 30-day jail sentence and placed Price on probation for two years, subject to
certain terms and conditions. Although he did not file a direct appeal of his conviction and
sentence, Price later petitioned for postconviction relief, which the state opposed and the
district court summarily denied.
2 The following summary of the undisputed facts relevant
to this appeal stems from the district court’s postconviction order, which is consistent with
the trial record.
During jury selection, the state exercised peremptory strikes of two potential
jurors—Juror 6 and Juror 1—each of whom identified as a racial minority. Price objected,
contending that the state’s use of two of its three peremptory strikes to remove potential
jurors from racial minority groups was improper under Batson v. Kentucky, 476 U.S. 79
(1986).3
1 Although the state also charged Price with additional crimes relating to the underlying
incident, the state later dismissed those charges under Minnesota Rule of Criminal
Procedure 30.01.
2 The same district court judge who presided over Price’s jury trial also considered and
summarily denied Price’s postconviction petition.
3 In Batson, the United States Supreme Court held that “the State’s privilege to strike
individual jurors through peremptory challenges[] is subject to the commands of the Equal
Protection Clause,” which “forbids the prosecutor to challenge potential jurors solely on
account of their race.” 476 U.S. at 89 (footnote omitted). The Supreme Court has explained
4
As to Juror 6, the state responded to Price’s Batson challenge by explaining that it
had exercised a peremptory strike “because Juror 6 ‘was on her phone for much of the
duration of voir dire and [the state believed] . . . that she [might] not pay attention during
trial.’” The district court determined that “this was an adequate, race-neutral reason to
exercise the challenge,” and Price ultimately withdrew his Batson objection regarding
Juror 6.
In response to Price’s Batson challenge concerning Juror 1—“who had reported
during voir dire that they were ‘excited to be part of the process’ of jury duty, had always
wanted to go through the experience, and ‘I like – watch [sic] TV crime shows’”—the state
asserted that it had exercised a peremptory strike “because the [potential] juror was excited
to be on the jury” and “people who are eager to be on the jury tend to read into things too
much.” Referring to convictions for driving while impaired (DWI), the state also
the three-step test for evaluating a challenge to the use of peremptory strikes under Batson
as follows:
. . . [O]nce the opponent of a peremptory challenge has made
out a prima facie case of racial discrimination (step one), the
burden of production shifts to the proponent of the strike to
come forward with a race-neutral explanation (step two). If a
race-neutral explanation is tendered, the trial court must then
decide (step three) whether the opponent of the strike has
proved purposeful discrimination.
Purkett v. Elem, 514 U.S. 765, 767 (1995); see also Minn. R. Crim. P. 26.02, subd. 7(3)
(codifying the three- step Batson peremptory challenge process). Effective March 1 and
July 1, 2025, Minnesota Rule of Criminal Procedure 26.02 was amended. Because these
amendments were not effective at the time the district court considered and ruled on Price’s
objections to the state’s use of its peremptory strikes during the November 2023 trial, our
citations to rule 26.02 herein refer to the version of the rule in existence before the 2025
amendments became effective.
5
maintained that it sought to remove Juror 1 because she “stated that her husband ha[d] two
DWIs.” Price countered that “leaving white persons on the jury panel who may have friends
or relatives with [DWI] history rendered the state’s reason a non-race-neutral one.” The
state replied by pointing to “a ‘notable difference’ in the lack of statements [by Juror 1]
taking accountability or agreement with the [DWIs],” by “specifically compar[ing] the voir
dire of Juror 1 with that of at least two other jurors who had expressed remorse for their
own alcohol-related offenses,” and by “reiterat[ing] its concerns about a potential juror
being ‘eager’ to be on a jury.”
The district court denied Price’s Batson challenge as to Juror 1, finding that the
state’s “primary reason” for exercising the peremptory strike was that Juror 1 had expressed
an “excitedness to be here, which was in contrast to many if not most of . . . the [potential]
jurors [who] were here.” And the district court cited the state’s explanation that Juror 1’s
excitedness “was something different” that the state was “entitled to consider[,] . . . as long
as it’s not an inappropriate reason.” The district court therefore determined that Price “had
not proven purposeful discrimination and [had] not established that the race-neutral reasons
given by the state were pretextual or that the real reason for the strike was based on
Juror 1’s race.”
In his postconviction petition, Price requested that the district court grant him a new
trial based on his claim that “his constitutional right to equal protection was violated when
the . . . court wrongly denied his Batson challenge at trial.”
As mentioned above, the district court summarily denied Price’s petition. In its
postconviction order, the district court quoted the Minnesota Supreme Court’s decision in
6
State v. Harvey for the proposition that “[a]ppellate courts afford great deference to a
district court’s Batson ruling because the record may not reflect all of the relevant
circumstances that the court may consider.” 932 N.W.2d 792, 811 (Minn. 2019) (quotation
omitted).
The district court determined that its “discussion on the record of its ruling did not
elaborate on the first Batson factor,” but noted that “[a]nalyzing a Batson challenge focuses
on factors two and three when the district court proceeded to address them.”
As to step two of the Batson analysis, the district court ruled that “the record does
not indicate the court erred at trial” because the state had “proffered a race-neutral
explanation”: Juror 1’s “degree of expressed eagerness to participate in jury duty.” The
district court observed that, “[w]hether the State’s reason is persuasive is irrelevant, as they
fulfilled their burden of production to provide a race-neutral explanation.”
And on step three, the district court determined that Price “did not demonstrate the
state’s reason was a pretext for racial discrimination” because “[t]here are no facts on
record compelling an inference of racial discrimination, and the State’s justification for its
decision sufficiently supports the Court’s initial ruling on . . . [Price’s] Batson defense.”
The district court noted that “demeanor can be [a] valid, race-neutral explanation[] for a
peremptory strike” and that it had “considered what the [potential] juror stated and the way
they expressed themselves about it.” And the district court decided that the state’s election
to strike Juror 1, who had “exhibited and expressed a noteworthily distinct demeanor and
attitude about being on a jury,” along with “the nature of the description of the [potential]
juror’s family member’s DWI history,” did not result in “an explanation so implausible or
7
fantastical that it suggest[ed] a pretext.” In addition, the district court quoted Harvey, 932
N.W.2d at 811 (quotation omitted), in stating that,
[e]ven if . . . [it] could have reached a different impression by
finding the state’s reason to be a pretext for racial
discrimination, . . . [Price] ha[d] not demonstrated from the
record that the court committed clear error overcoming the
“great deference” it is granted when reviewing a Batson
challenge by reaching a different result than that advocated by
[Price].
Price appeals.
DECISION
Price contends that the district court abused its discretion in denying his petition for
postconviction relief because (1) the court applied deferential review to its decision to deny
his Batson challenge and (2) the state’s peremptory strike was motivated by racial
discrimination and its proffered explanation for removing the potential juror was
pretextual.
Our review of a postconviction proceeding is limited to determining whether the
evidence is sufficient to sustain the findings of the postconviction court. Scruggs v. State,
484 N.W.2d 21, 25 (Minn. 1992). A “postconviction proceeding is a collateral attack on a
judgment which carries a presumption of regularity and which, therefore, cannot be lightly
set aside.” State ex rel. Gray v. Tahash, 156 N.W.2d 228, 229 (Minn. 1968) (footnote
omitted). Appellate courts “review a [district] court’s summary denial of a petition for
postconviction relief for an abuse of discretion.” Andersen v. State, 913 N.W.2d 417, 422
(Minn. 2018). “A postconviction court abuses its discretion when it has exercised its
discretion in an arbitrary or capricious manner, based its ruling on an erroneous view of
8
the law, or made clearly erroneous factual findings.” Ries v. State, 920 N.W.2d 620, 627
(Minn. 2018) (quotation omitted). Appellate courts review the district court’s “legal
conclusions de novo and its findings of fact for clear error.” Rhodes v. State, 875 N.W.2d
779, 786 (Minn. 2016).4
As noted above, the United States Supreme Court’s decision in Batson “articulated
a three-step process for courts to follow in assessing whether a peremptory strike runs afoul
of equal protection principles.” State v. Lufkins, 963 N.W.2d 205, 209 (Minn. 2021) (citing
Batson, 476 U.S. at 96–98) (other citation omitted); see also Minn. R. Crim. P. 26.02,
subd. 7(3)(a)–(c). “[C]larity at each step of the Batson analysis is important because the
objecting party has the burden of proving a prima facie case, the proponent has the burden
of production of a race-neutral explanation, and the objecting party has the ultimate burden
of proving pretext and discriminatory intent.” Harvey, 932 N.W.2d at 811 (quotation
omitted). “[G]enerally [,] a district court should make its rulings sequentially at the
conclusion of its consideration of each prong, including whether the challenger has
established a prima facie case, before considering prongs two and three.” State v. Onyelobi,
879 N.W.2d 334, 347 n.11 (Minn. 2016).
4 A district court must hold an evidentiary hearing on a postconviction petition “[u]nless
the petition and the files and records of the proceeding conclusively show that the petitioner
is entitled to no relief.” Minn. Stat. § 590.04, subd. 1 (2024). “In determining whether an
evidentiary hearing is required, a [district] court considers the facts alleged in the petition
as true and construes them in the light most favorable to the petitioner.” Andersen, 913
N.W.2d at 422–23 (quotation omitted). In this appeal, Price does not challenge the district
court’s decision to decide his postconviction petition without affording him an evidentiary
hearing.
9
More specifically, “[a]t step one, the party objecting to a peremptory strike has the
burden to make a prima facie showing of racial discrimination” by establishing “that one
or more members of a racial group have been peremptorily excluded from a jury and that
the circumstances of the case raise an inference that the exclusion was based on race.”
Lufkins, 963 N.W.2d at 209 (citation and quotation omitted).
When an “objecting party makes the required prima facie showing” at the first step,
the court’s analysis proceeds to the second step, at which “the burden shifts to the striking
party to articulate a race-neutral explanation for exercising the peremptory challenge.” Id.
at 209–10 (quotation and citation omitted). Although the proffered explanation at the
second step “must be related to the particular case to be tried,” as well as “clear and
reasonably specific,” it need not be “persuasive, or even plausible,” and it “does
not . . . have to be valid in the sense of establishing a reasonable basis for a strike.” Id. at
210, 211 (quotations omitted). Courts deem the proffered reason to be “race-neutral unless
a discriminatory intent is inherent in the prosecutor’s explanation.” Id. at 210 (quotation
omitted).
At the third step, “the district court must determine whether the objecting party has
carried his burden of proving purposeful discrimination” by showing “that the peremptory
challenge was motivated by racial discrimination and that the striking party ’s proffered
explanation was merely a pretext for the discriminatory motive.” Id. (quotations omitted).
“The objecting party ultimately carries the burden of persuasion to demonstrate the
existence of purposeful discrimination; this burden never shifts from the opponent of the
peremptory challenge.” Id. (quotation omitted).
10
As the district court observed in its postconviction order, “[a] district court’s ruling
on a Batson challenge receives great deference because the record may not reflect all of the
relevant circumstances that the court may consider.” Harvey, 932 N.W.2d at 811
(quotations and citation omitted). While appellate courts will not ordinarily reverse a
district court’s Batson determination “unless it is clearly erroneous,” appellate courts
“examine the record without deferring to the district court’s analysis” when “the district
court makes its determinations using the wrong legal standard.” Id. (quotations and
citations omitted).
The Minnesota Supreme Court has explained, however, that a district court’s failure
to rule sequentially at the conclusion of each step of the Batson analysis does not require
appellate courts to alter the usual deferential standard of review when the district court does
not conflate the legal standards for each step. Onyelobi, 879 N.W.2d at 347 n.11; see also
Harvey, 932 N.W.2d at 811 (citing Onyelobi for this principle). And we have held that “a
district court’s failure to exactly follow the three-step process for analyzing a Batson
challenge is not a Batson violation” and that “[a] district court’s failure to articulate the
Batson-challenge analysis according to Minn. R. Crim. P. 26.02, subd. 7(3) may be
harmless error.” State v. Rivers, 787 N.W.2d 206, 211–12 (Minn. App. 2010) (citation
omitted), rev. denied (Minn. Oct. 19, 2010).
With these legal standards in mind, we address each of Price’s contentions in turn.
11
I. The district court acted within its discretion in reviewing its decision to deny
Price’s Batson challenge.
Price asserts that the district court abused its discretion by applying deferential
review to its own Batson ruling. He maintains that, because the district court did not make
a ruling at each step of the Batson analysis when it denied Price’s challenge during jury
selection, neither the district court nor this court may apply a deferential standard of review.
For two reasons, this argument is unavailing.
First, the district court’s explanation of its primary bases for denying Price’s
postconviction petition establishes that it “examine[d] the record without deferring to [its]
analysis” in rejecting Price’s Batson challenge during jury selection. Harvey, 932 N.W.2d
at 811 (quotations and citations omitted). In its postconviction order, the district court
reviewed the record as to all three steps of the Batson peremptory challenge process and
made determinations on each step that do not reflect deferential review. While the district
court did quote the appellate “great deference” standard set forth in Harvey, the court only
cited Harvey and referenced deference in its alternative reasoning on step three of the
Batson analysis. Id. (quotation omitted). Indeed, the district court established that reasoning
as alternative by prefacing it with the clause, “[e]ven if the court could have reached a
different impression by finding the state’s reason to be a pretext for racial discrimination,”
before quoting Harvey, 932 N.W.2d at 811 (quotation omitted), in stating its auxiliary
determination that Price had “not demonstrated from the record that the court committed
clear error overcoming the ‘great deference’ it is granted when reviewing a Batson
challenge by reaching a different result than that advocated by [Price].”
12
Second, the district court’s alternative reasoning applying deferential review to step
three of the Batson analysis was not improper. Price mainly relies on the Minnesota
Supreme Court’s decision in State v. Pendleton, 725 N.W.2d 717, 727 (Minn. 2007), 5 for
the proposition that, “[w]hen a district court does not make a ruling at each step in the
process, the reviewing court must examine the record without deferring to the district
court’s analysis.” Although the supreme court did refrain from applying deferential review
in Pendleton, in which “the district court [had] collapsed the Batson analysis into one step,”
725 N.W.2d at 727, the supreme court later distinguished Pendleton in Onyelobi, in which
“the district court did not conflate the three prongs so as to obscure its discrete analysis of
each prong,” such that the supreme court did not need to alter the usual deferential standard
of review , 879 N.W.2d at 347 n.11. Thus, while the supreme court in Onyelobi
“reaffirm[ed] that . . . the optimal procedure” is for district courts to rule sequentially at the
conclusion of their consideration of each step in the Batson peremptory challenge process,
the supreme court did not forbid deferential review when a discrete analysis of each prong
is apparent from the record. 879 N.W.2d at 347 n.11.
The district court’s postconviction order described the court’s discrete analysis at
the third step of the Batson process in rejecting Price’s challenge to the state’s exercise of
5 Price also cites our decision in State v. Seaver, 820 N.W.2d 627, 633 (Minn. App. 2012)
(declining to apply deferential review because “the district court did not follow Batson
precedent or procedure when it did not rule at each step of the Batson analysis” (citing
Pendleton, 725 N.W.2d at 725–26)). For the same reasons as expressed below concerning
our analysis of Pendleton, we conclude that Price’s reliance on Seaver is unconvincing.
13
the peremptory strike to Juror 1 during jury selection.6 As to the third step—whether Price
had “carried his burden of proving purposeful discrimination” by showing “that the
peremptory challenge was motivated by racial discrimination and that the . . . [state’s]
proffered explanation was merely a pretext for the discriminatory motive,” Lufkins, 963
N.W.2d at 210 (quotations omitted)—the district court found that the state’s explanation
that Juror 1’s excitedness “was something different” that the state was “entitled to
consider[,] . . . as long as it’s not an inappropriate reason,” and that Price “had not proven
purposeful discrimination and [had] not established that the race-neutral reasons given by
the state were pretextual or that the real reason for the strike was based on Juror 1’s race.”
Thus, consistent with Onyelobi and under the unique circumstances of this case, the district
court did not base its ruling on an erroneous view of the law by applying deferential review
in its alternative reasoning on step three of the Batson analysis.7 See Ries, 920 N.W.2d at
627.
We therefore conclude that the district court acted within its discretion in reviewing
its decision to deny Price’s Batson challenge.
6 Here, we focus our analysis on the third Batson step because that was the only step at
which the district court applied deferential review in its order denying Price’s petition for
postconviction relief.
7 For the reasons discussed in section II, below, even if the district court did abuse its
discretion by applying deferential review in its alternative reasoning on step three, we
would conclude that it was harmless error. See Rivers, 787 N.W.2d at 211–12 (concluding
that “the district court did not err by denying the Batson challenge in this case and that
failure to strictly follow the rules was harmless error”).
14
II. The district court acted within its discretion in denying Price’s postconviction
petition.
Price asserts that the district court abused its discretion in denying his
postconviction petition because the state’s peremptory challenge was motivated by racial
discrimination and the state’s proffered explanation was clearly pretextual. We discern no
abuse of discretion by the district court on these bases. Although the district court’s
rejection of Price’s Batson challenge during jury selection is accorded “great deference”
and ordinarily not subject to reversal “unless it is clearly erroneous,” we need not rely on
that deference to affirm the district court’s postconviction order given the record before us.
Harvey, 932 N.W.2d at 811 (quotations and citations omitted).
The district court acknowledged in its postconviction order that its “discussion on
the record of its ruling did not elaborate on the first Batson factor.” But the district court
acted within its discretion in determining that “[a]nalyzing a Batson challenge focuses on
factors two and three when the district court proceeded to address them.” By addressing
the second and third steps of the Batson analysis, the district court implicitly determined
that Price had met his “burden to make a prima facie showing of racial discrimination” by
establishing “that one or more members of a racial group [had] been peremptorily excluded
from [the] jury and that the circumstances of the case raise[d] an inference that the
exclusion was based on race.” Lufkins, 963 N.W.2d at 209 (citation and quotation omitted);
see also Rivers, 787 N.W.2d at 211 (observing that “the district court implicitly determined
that [the defendant] had established a prima facie case by asking the prosecutor whether he
could articulate a race -neutral reason for the strike after [the defendant] asserted the
15
challenge based on the prosecutor’s strike of the only African American on the jury panel”).
Consistent with the Minnesota Supreme Court’s analysis in Lufkins, we “do not consider
step one further ,” given that any “question as to step one is moot on appeal because the
district court proceeded to steps two and three of the analysis. ” 963 N.W.2d at 210
(citations omitted).
On step two of the Batson analysis, the district court acted within its discretion in
determining in the postconviction order that “the record does not indicate the court erred
at trial” because the state had “proffered a race-neutral explanation”: Juror 1’s “degree of
expressed eagerness to participate in jury duty.” When it denied Price’s Batson challenge
during jury selection, the district court found that the state’s “primary reason” for
exercising the peremptory strike was that Juror 1 had expressed an “excitedness to be here,
which was in contrast to many if not most of . . . the [potential] jurors [who] were here.”
The state’s proffered reason—which included its “belief that, ‘ in general, people
who are eager to be on the jury tend to read into things too much’”—was a “clear,”
“reasonably specific,” and “race -neutral explanation for exercising the peremptory
challenge” that was “related to the particular case to be tried.” Id. (citation and quotations
omitted). This is because there is no “discriminatory intent . . . inherent in the prosecutor’s
explanation” concerning Juror 1’s desire to serve on the jury in this matter. Id. (quotation
omitted). And because, at the second step, the state’s proffered explanation did not need to
be “persuasive, or even plausible,” and did “not . . . have to be valid in the sense of
establishing a reasonable basis for a strike,” id. (quotations omitted), the district court did
not abuse its discretion by observing in the postconviction order that, “[w]hether the State’s
16
reason is persuasive is irrelevant, as they fulfilled their burden of production to provide a
race-neutral explanation.”
We reach the same conclusion about the district court’s determination in the
postconviction order that, on step three, Price “did not demonstrate the state’s reason was
a pretext for racial discrimination” because “[t]here are no facts on record compelling an
inference of racial discrimination, and the state’s justification for its decision sufficiently
supports the court’s initial ruling on . . . [Price’s] Batson defense.” During jury selection,
the district court denied Price’s Batson challenge based on its finding that state’s
explanation that Juror 1’s excitedness “was something different” that the state was “entitled
to consider[,] . . . as long as it’s not an inappropriate reason,” and that Price “had not proven
purposeful discrimination and [had] not established that the race-neutral reasons given by
the state were pretextual or that the real reason for the strike was based on Juror 1’s race.”
In its postconviction order, the district court properly noted that “demeanor can be
[a] valid, race-neutral explanation[] for a peremptory strike.” See id. (observing that
“demeanor can be [a] valid, race-neutral explanation[] for a peremptory strike (citations
omitted)); see also Snyder v. Louisiana, 552 U.S. 472, 477 (2008) (“[R]ace-neutral reasons
for peremptory challenges often invoke a juror’s demeanor . . . .”). The district court also
appropriately considered “what the [potential] juror stated and the way they expressed
themselves about it.” See Snyder, 552 U.S. at 477 (noting that, when a juror’s demeanor is
offered as the basis for a peremptory strike, “the trial court’s firsthand observations [are]
of even greater importance” and the court “must evaluate . . . whether the juror’s demeanor
can credibly be said to have exhibited the basis for the strike attributed to the juror by the
17
prosecutor”). And we discern no abuse of discretion in the district court’s postconviction
ruling that the state’s decision to strike Juror 1 based on the potential juror’s exhibition and
expression of “a noteworthily distinct demeanor and attitude about being on a jury” did not
render the state’s proffered explanation “so implausible or fantastical that it suggest[ed] a
pretext.” Given this record, we cannot say that the district court’s postconviction order
reflects an arbitrary or capricious exercise of discretion, an erroneous view of the law, or
clearly erroneous factual findings in determining that Price had not “carried his burden of
proving purposeful discrimination” by showing “that the peremptory challenge was
motivated by racial discrimination and that the . . . [state’s] proffered explanation was
merely a pretext for the discriminatory motive.” 8 Lufkins, 963 N.W.2d at 210 (quotations
omitted); see also Ries, 920 N.W.2d at 627.
8 Steps two and three of the Batson analysis require evaluation of “a race-neutral
explanation for exercising the peremptory challenge.” Lufkins, 963 N.W.2d at 209–10
(emphasis added) (quotations and citation omitted). Price has cited no authority requiring
appellate courts to evaluate more than one race-neutral explanation in cases concerning
multiple proffered reasons for a peremptory strike, and we are aware of none. Cf.
Pendleton, 725 N.W.2d at 725 n.4 (declining to analyze a basis for a peremptory strike by
the state that the district court considered but the state did not offer as a race-neutral reason
for the strike). In Lufkins, the supreme court explained that “Snyder requires that the district
court clearly state which of the prosecutor’ s proffered race-neutral reasons it found to be
credible enough to withstand the Batson objection.” 963 N.W.2d at 213. The district court’s
postconviction order clearly establishes that the court found both of the state’s proffered
explanations—Juror 1’s excitedness to serve on the jury and her statements about her
husband’s DWIs—to be sufficiently credible for purposes of Batson. But because we
conclude that the district court acted within its discretion in denying Price’s postconviction
petition based on its determinations as to the state’s proffered explanation about Juror 1’s
“expressed eagerness to participate in jury duty”—the explanation that the court primarily
addressed in the “Analysis” section of the postconviction order— we decline to address
Price’s arguments about the state’s additional proffered explanation concerning Juror 1’s
statements about her husband’s DWIs.
18
Consequently, we conclude that the district court acted within its discretion in
denying Price’s postconviction petition.
Affirmed.