If striking *all* black jurors from a capital case is not a Batson violation, I don’t know what is. The only problem of course, is that SCOTUS’ bar is so low, all a prosecutor has to do is offer some putatively non-race-based reason for striking a juror, no matter how irrelevant or inane (i.e., hairstyle, clothing), to avoid violating Batson. It will be interesting to see how the Court rules.