Mitchell v. People

Holding

A Black juvenile prosecuted as an adult for felony murder argued that the district attorney selectively prosecuted him on the basis of race: of four equally-charged teenagers, the two Black defendants were charged with murder in adult court while the two non-Black codefendants were transferred to juvenile court and offered pleas. He supported the claim with national, state, and district-level statistics on the disproportionate arrest, adult prosecution, and incarceration of Black youth. The court affirmed dismissal of the claim, holding he showed neither discriminatory effect nor discriminatory purpose: he was not "similarly situated" to the codefendants (he was the shooter), and — the proposition that matters for the science — "[s]tandalone statistical evidence, without a showing that those involved were similarly situated, seldom suffices to prove discriminatory effect" (¶ 38), nor does it establish discriminatory purpose (¶ 46). The case is the clearest recent statement of what population-level disparity evidence can and cannot do inside an equal-protection claim in the juvenile context.