Rivera v. Illinois

Michael Rivera (defendant) was charged with first-degree murder. During jury selection, Rivera tried to use a peremptory challenge to remove juror Deloris Gomez, but the trial judge denied it, suspecting the strike was racially discriminatory. Nobody disputed that Gomez was qualified or actually biased against Rivera. Rivera was convicted, and the Illinois Supreme Court agreed the challenge should have been allowed but treated the error as harmless rather than reversing.