context: On appeal, the California Supreme Court majority accepted the term "systematic exclusion" as "an acceptable shorthand phrase for denoting [Batson/]Wheeler error."
citation_a.signal: see
citation_a.parenthetical: "[T]he trial court's ruling that it was necessary to show a 'systematic exclusion' of prospective jurors was incorrect, as the Constitution forbids striking a single juror for a discriminatory purpose[.]"
citation_a.sentence: See Batson, 476 U.S. at 95-96, 106 S.Ct. 1712 (“For evidentiary requirements to dictate that several must suffer discrimination before one could object, would be inconsistent with the promise of equal protection to all.” (internal quotation and citation omitted)); Sims v. Brown, 425 F.3d 560, 574 (9th Cir.2005), amended 430 F.3d 1220 (“[T]he trial court’s ruling that it was necessary to show a ‘systematic exclusion’ of prospective jurors was incorrect, as the Constitution forbids striking a single juror for a discriminatory purpose[.]”); United States v. De Gross, 913 F.2d 1417, 1425 (9th Cir.1990) (“Although showing a pattern of systematic exclusion is one way of giving rise to an inference of discrimination, it is not the only way.”); see also People v. Fuentes, 54 Cal.3d 707, 286 Cal. Rptr. 792, 818 P.2d 75, 80 n. 4 (1991) (“The term [systematic exclusion] is not apposite in the Wheeler context, for a single discriminatory exclusion may violate a defendant’s right to a representative jury.” (emphasis added)).
citation_b.signal: see also
citation_b.parenthetical: "The term [systematic exclusion] is not apposite in the Wheeler context, for a single discriminatory exclusion may violate a defendant's right to a representative jury." (emphasis added
citation_b.sentence: See Batson, 476 U.S. at 95-96, 106 S.Ct. 1712 (“For evidentiary requirements to dictate that several must suffer discrimination before one could object, would be inconsistent with the promise of equal protection to all.” (internal quotation and citation omitted)); Sims v. Brown, 425 F.3d 560, 574 (9th Cir.2005), amended 430 F.3d 1220 (“[T]he trial court’s ruling that it was necessary to show a ‘systematic exclusion’ of prospective jurors was incorrect, as the Constitution forbids striking a single juror for a discriminatory purpose[.]”); United States v. De Gross, 913 F.2d 1417, 1425 (9th Cir.1990) (“Although showing a pattern of systematic exclusion is one way of giving rise to an inference of discrimination, it is not the only way.”); see also People v. Fuentes, 54 Cal.3d 707, 286 Cal. Rptr. 792, 818 P.2d 75, 80 n. 4 (1991) (“The term [systematic exclusion] is not apposite in the Wheeler context, for a single discriminatory exclusion may violate a defendant’s right to a representative jury.” (emphasis added)).