State v. Webster, 2001 S.D. 141

In State v. Webster, the defendant was convicted of grand theft by deception and appealed, arguing that the State engaged in unconstitutional gender discrimination during jury selection. Specifically, the prosecution used seven of its ten peremptory strikes to remove female jurors. The defendant claimed this was based on the stereotype that women would be more sympathetic toward him because he was a young and attractive man. The Supreme Court of South Dakota held that the trial court properly rejected the defendant’s challenge. While gender-based discrimination in jury selection is unconstitutional under J.E.B. v. Alabama ex rel. T.B., 511 U.S. 127 (1994), the Court found that the prosecution offered sufficient gender-neutral reasons for the strikes. These included concerns about jurors’ lack of education, prior legal troubles, and financial difficulties that might predispose them against the State. Because these explanations were deemed legitimate and unrelated to gender, the Supreme Court affirmed the trial court’s decision and upheld the conviction. This case applied the Batson and J.E.B. framework to claims of gender-based jury discrimination. It reaffirms that while the Constitution prohibits peremptory strikes motivated solely by gender, prosecutors may rely on neutral factors such as education, legal history, or financial hardship when exercising challenges. It highlights the evidentiary burden on defendants to show purposeful gender discrimination in jury selection.

Topics

• Gender discrimination

Geographical location

• North America
• United States
• South Dakota

Keywords

• Batson
• gender stereotypes
• jury selection
• peremptory challenge

Year

• 2001

External URL

• State v. Webster, 2001 S.D. 141

Court

• Supreme Court of South Dakota

Type

• Domestic Case Law

Jurisdiction

• South Dakota