In a death penalty case, the California Supreme Court concluded that the trial court improperly excused at least four prospective jurors for cause and reversed the defendant’s death sentence while affirming his conviction. In a capital case, the erroneous excusal of even one prospective juror for cause requires automatic reversal of the death sentence, although not the guilt determinations. Witherspoon v. Illinois (1968) 391 U.S. 510. A jury in Los Angeles convicted defendant for kidnapping, robbing, raping, torturing, and murdering a 45-year-old woman and returned a death verdict. The prosecutor also struck four black male jurors, leaving no black man on the jury.
Defendant Jamelle Edward Armstrong, a black man, was sentenced to death for raping, torturing, and murdering Penny Sigler, a white woman. Armstrong objected to the prosecutor’s peremptory strikes of four black men in the jury panel. (See Batson v. Kentucky (1986) 476 U.S.; People v. Wheeler (1978) 22 Cal.3d 258. The prosecutor gave reasons for each strike, and the trial court rejected Armstrong’s Batson claims.