2017] POLICING THE BOUNDARIES OF WHITENESS 1115
Zimmerman, a 28-year-old man of white American and Peruvian descent,
claiming they found no evidence to contradict Zimmerman’s assertion that
he acted in self-defense after Martin attacked him.2 Evidence later revealed
that Zimmerman, who saw Martin walking in the neighborhood as he was
driving to Target, called 911 to report Martin as a “suspicious person,” but
then disregarded the 911 operator’s directives to remain in his car and leave
Martin alone.3 Instead, Zimmerman chased, confronted, and ultimately shot
and killed Martin after a physical struggle.4 Evid ence al so show ed that Martin ,
who had no criminal record, was simply returning to the home of Brandy
Green, where he was a guest; Green, a resident of the Retreat at Twin Lakes,
was the girlfriend of Martin’s father, Tracey Martin.5 At the time of his death,
Martin had nothing on his person but his cellphone, an Arizona watermelon
soda, a bag of Skittles, $40.15 in cash, a cigarette lighter, and some
The death of Trayvon Martin inspired nationwide conversations about
racism, racial profiling, implicit bias, police brutality, and numerous
inequities in the criminal justice system.7 Martin’s death also sparked
2. CJR Staff, Reporting Trayvon, COLUM. JOURNALISM REV. (Apr. 2, 2012), http://www.cjr.org/
behind_the_news/reporting_trayvon.php; History of Racial Tension for Sanford and Blacks, GRIO (Mar.
23, 2012, 8:31 AM), http://thegrio.com/2012/03/23/history-of-racial-tension-for-fla-city-and-blacks.
3. Trayvon Martin Shooting Fast Facts, CNN (Feb. 7, 2016, 4:25 PM), http://www.cnn.com/
5. See LISA BLOOM, SUSPICION NATION: THE INSIDE STORY OF TH E TRAYVON MARTIN
INJUSTICE AND WHY WE CONTINUE TO REPEAT IT 39 (2014).
6. Teresa M. Bruce, Terrorism Du Jour: How the Trayvon Martin Case Exposes an Endemic
Regime of Fear That Keeps Black Males and Females of All Colors in a State of Subjugation, 21 UCLA
WOMEN’S L.J. 1, 6 (2014).
7. See, e.g., Valena Elizabeth Beety, What the Brain Saw: The Case of Trayvon Martin and the
Need for Eyewitness Identification Reform, 90 DENV. U. L. REV. 331, 331 (examining “the role of
memory and perception in the death of Trayvon Martin and in eyewitness identification in
criminal cases” and suggesting reforms to avoid witness misidentifications); Mark S. Brodin, The
Murder of Black Males in a World of Non-Accountability: The Surreal Trial of George Zimmerman for the
Killing of Trayvon Martin, 59 HOW. L.J. 765, 767 (2016) (examining the trial of George
Zimmerman and highlighting how the “prosecutors committed the most inexplicable strategic
and evidentiary blunders of a type that experienced prosecutors would very likely not commit in
a more earnest effort to convict the accused”); Bruce, supra note 6, at 2 (exploring “the depth of
suffering caused by unprovoked, racially or sexually motivated, aggression” and analogizing that
“sort of aggression to terrorism”); Cynthia Lee, (E)Racing Trayvon Martin, 12 OHIO ST. J. CRIM. L.
91, 95 (2014) (arguing that the best way to overcome the employment of stereotypes and bias in
the criminal justice system is to “call attention to race to encourage jurors to consciously combat
stereotypical thinking”); Cynthia Lee, Making Race Salient: Trayvon Martin and Implicit Bias in a Not
Yet Post-Racial Society, 91 N.C. L. REV. 1555, 1555, 1564 (2013) [hereinafter Making Race Salient]
(proposing “that prosecutors and criminal defense attorneys who are concerned about the
operation of implicit racial bias should attempt to make race salient in the criminal courtroom”
because “calling attention to the relevance of race in a given situation encourages individuals to
suppress what would otherwise be automatic, stereotypic congruent responses in favor of acting
in a more egalitarian manner”); Camille Gear Rich, Angela Harris and the Racial Politics of
Masculinity: Trayvon Martin, George Zimmerman, and the Dilemmas of Desiring Whiteness, 102 CALIF. L.