Pitchford v. Cain · ¶34

Should a defendant make a prima facie case, the court then moves to step two. There, “the prosecution must offer a race-neutral basis” for each strike. Snyder, 552 U. S., at 476–477 (internal quotation marks omitted). If the prosecution does so, the court proceeds to step three: The defendant can try to rebut the prosecution's race-neutral reasons as “pretextual,” and ultimately the court must determine whether the prosecution's strikes were in fact based on purposeful discrimination. Id., at 477, 485. As at step one, defendants commonly use statistical and comparative juror arguments at step three.

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