In the case of James Purkett, Superintendent, Farmington Corrections Center v. Jimmy Elem in 1994, the U.S Supreme Court addressed issues related to racial discrimination during jury selection. The respondent, Jimmy Elem who was an African-American inmate at a Missouri prison filed a lawsuit against prison officials for injuries sustained from another prisoner's attack. During jury selection for this civil rights suit, two black jurors were struck by peremptory challenges issued by petitioner’s counsel without providing race-neutral reasons when asked by trial court judge. This led to an all-white jury and subsequently ruled in favor of the petitioner (prison official). On appeal, it was argued that these actions violated Batson v Kentucky which prohibits using peremptory strikes on potential jurors based solely on their race. The Supreme Court held that under Batson framework if defendant makes prima facie showing of discriminatory intent and prosecutor provides race-neutral explanation then burden shifts back to defendant to prove purposeful racial discrimination occurred; however lower courts erred as they did not require respondent (Elem) to carry this burden but instead evaluated whether proffered explanations were plausible which is not required under Batson standard.

In the dissenting opinion for James Purkett, Superintendent, Farmington Corrections Center v. Jimmy Elem (1994), Justice Stevens argued that the majority's decision undermined Batson v. Kentucky by allowing a prosecutor to give any reason at all for striking jurors based on race, no matter how implausible or nonsensical it may be. In this case, the prosecutor struck two black jurors because of their long hair and mustaches which he associated with criminal behavior; reasons Justice Stevens found to be pretexts for racial discrimination. He believed that such flimsy justifications should not satisfy a prosecutor’s burden of providing a legitimate non-discriminatory reason for using peremptory challenges against minority jurors as required under Batson ruling. The majority's acceptance of these reasons set an alarming precedent where prosecutors could easily bypass anti-discrimination laws simply by offering trivial explanations.