In Snyder v. Louisiana, 552 U.S. 472 (2008), a capital murder case, the prosecution offered two reasons for striking an African-American juror: (1) the juror's nervous demeanor and; (2) concern that, due to his student-teaching obligations, the juror might be inclined to convict the defendant of a lesser offense in order to avoid a penalty phase and thereby shorten the trial. Id. at 1208. The trial court upheld the strikes without explanation, and never made a finding on the record regarding the juror's demeanor. Id. at 1208-1209. After finding that the prosecution's second stated reason was pretextual (id. at 1209-1212), the United States Supreme Court, noting, inter alia, the "absence of anything in the record showing that the trial judge credited the claim that the juror was nervous," concluded that the record did not show that the prosecution would have struck the juror based on his nervous demeanor alone. In Snyder v. Louisiana, the prosecutor sed five of his 12 peremptories to eliminate all African-American jurors from the panel of 36 prospective jurors. (Id. at p. 476.) In a third-stage review of the prosecutor's reasons for challenging one particular prospective juror (his apparent nervousness and time constraints), the Court held the trial court's failure to state whether it shared the prosecutor's perception made it impossible to review the individual's nervousness as a proposed justification. (Id. at p. 479.) Because the alleged time-constraint justification did not differ from the circumstances of non-African-American jurors who were not excused, the Court described that justification as "highly speculative," "suspicious" and "implausible." (Id. at pp. 482-483.) Considering these factors in tandem, the Court concluded the prosecutor's justification was pretextual and masked a discriminatory intent. (Id. at p. 485.)