After being struck in the head with a metal handlebar, called the n-word, and having his life threatened by four white men in Lewiston, Me., Black man retrieves a gun from his home nearby, returns to the scene, and fires a shot into a dirt pile. At trial, the prosecutor peremptorily struck the only person of color from the jury pool. Man: this is discrimination and violates Batson v. Kentucky. Trial court: "I can't make any findings." Man is convicted and sentenced to three years in prison. First Circuit: It's "concerning" that in a case with racial overtones, the only Black potential juror in the 32-person venire was struck for a seemingly trivial reason of only having an 11th grade education. But habeas denied.