Allen v. Hardy
In Allen v. Hardy, 478 U.S. 255, 106 S.Ct. 2878, 92 L.Ed.2d 199 (1986), the Supreme Court recognized that "other mechanisms existed prior to the decision in Batson, creating a high probability that the individual jurors seated in a particular case were free from bias." Id. at 259, 106 S.Ct. at 2880.
The Supreme Court concluded that the new procedures established in Batson thus did not have "such a fundamental impact on the integrity of the jury's factfinding as to compel retroactive application." Id.