Flowers v. Mississippi
Legal Issues
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Overview
Curtis Flowers was tried six times for the same quadruple murder in Winona, Mississippi, with the same prosecutor using peremptory strikes to remove virtually every Black prospective juror across the trials. The Supreme Court reversed 7-2 in 2019, finding that the history of race-based juror exclusion across all six trials was directly relevant to assessing whether the sixth trial violated Batson v. Kentucky. The decision is notable for permitting cross-trial analysis of a prosecutor's pattern of discriminatory strikes.
The Facts
Curtis Flowers was tried six times for the 1996 murders of four employees at a furniture store in Winona, Mississippi. Flowers is Black; three of the four victims were white. Across the trials, prosecutors used their peremptory strikes to remove nearly all the Black prospective jurors available to strike.
The Application
The Court weighed the history of race-based strikes across Flowers's trials, a sharp disparity in how the State questioned Black versus white prospective jurors at the sixth trial, and the State's decision to strike Wright despite her similarity to accepted white jurors, and found this combination showed purposeful discrimination.
The Conclusion
Conclusion
The Supreme Court reversed 7-2, holding that a prosecutor's pattern of race-based juror strikes across multiple trials is relevant to assessing Batson violations. The decision permitted cross-trial analysis to evaluate whether systematic exclusion of Black jurors demonstrated intentional discrimination, rather than evaluating each trial in isolation.
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