What showing must a trial court make to demonstrate a 'sensitive inquiry' under Batson v. Kentucky?

QUESTION PRESENTED When the defense challenges a prosecutor’s exercise of a peremptory strike of a prospective juror under Batson v. Kentucky, 487 U.S. 79, 106 S.Ct. 1712 (1986), the trial court “must undertake ‘a sensitive inquiry into such circumstantial and direct evidence of intent as may be available.’” (Batson, 487 U.S. at 106, S.Ct. at 1721 (1986); accord, Thaler v. Haynes 559 U.S. 43, 48, 130 S.Ct. 1171, 1174 (2010.)) The California Supreme Court instead requires a trial court in a Batson situation to make “a sincere and reasoned effort to evaluate the nondiscriminatory justifications offered” by the prosecutor for dismissing a minority prospective juror. (People v. Ward, 36 Cal.4th 186, 200, 30 Cal. Rptr.3d 464, 475 (2005.)) While California’s standard may appear to be in accord with this Court’s exacting “sensitive inquiry” standard, in application it is not. In the great majority of California cases involving a Batson error issue, as here, the trial court’s perfunctory finding of no discrimination is upheld by the reviewing Court. Thus, the following important question arises: What of-record showing must a trial court make to demonstrate that it has made Batson’s “sensitive inquiry” into the prosecutor’s explanations for dismissing a minority prospective juror? PARTIES AND