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Hines v. City of Columbus

United States Court of Appeals for the Sixth Circuit
676 Fed. Appx. 546 (2017)


Facts

Joseph Hines (plaintiff), who was African American, sued the City of Columbus (defendant), alleging that police officers used excessive force arresting him. The prospective juror pool included only two African Americans. Hines’s attorney did not object when the city attorney used a peremptory strike to remove the first one but objected to the second, arguing that striking both showed a racial pattern. The city attorney offered a race-neutral reason for the second strike that the judge accepted and then overruled the objection, but Hines’s attorney did not insist that the city attorney also provide a race-neutral reason for striking the first. The jury found that the police used excessive force and awarded Hines $30,000 in damages plus attorneys’ fees over $75,000. Hines sought a larger damage award and appealed for a new trial, arguing that the city attorney used peremptory strikes on the basis of race in violation of Batson v. Kentucky, 476 U.S. 79 (1986).

Rule of Law

Issue

Holding and Reasoning (Suhrheinrich, J.)

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