People v. Bell

In this case, we consider whether the trial court failed to follow the three-step process of Batson v Kentucky, 476 US 79; 106 S Ct 1712; 90 L Ed 2d 69 (1986), when it prohibited defendant from exercising his right to two peremptory challenges and, if so, whether that error is structural and, thus, requires automatic reversal. In Batson, the United States Supreme Court held that a peremptory challenge to strike a juror may not be exercised on the basis of race. Id. at 89, 96-98. The Court set forth a three-step process for determining whether a challenger has improperly exercised peremptory…