Dixon v. State
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The Supreme Court affirmed Defendant's conviction for fourth-degree arson, holding that although the district court clearly erred in rejecting Defendant's Batson objection to the State's use of a peremptory challenge to remove a prospective alternate juror based on gender, the error was harmless.
Defendant was convicted of fourth-degree arson. At issue on appeal was whether a discriminatory peremptory challenge used to remove a prospective alternate juror constituted structural error requiring reversal if no alternate deliberated with the jury. The Supreme Court held (1) there were compelling reasons to apply harmless-error review under these circumstances; and (2) the district court's error in rejecting Defendant's Batson objection to the prospective alternative juror based on gender, but the error was harmless because no alternate deliberated with the jury.
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