Norris v. Alabama | |
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Argued February 15,18, 1935 Decided April 1, 1935 | |
Full case name | Norris v. Alabama |
Citations | 294 U.S. 587 ( more ) 55 S. Ct. 579; 79 L. Ed. 1074 |
Holding | |
Exclusion of blacks from a grand jury by which an African-American is indicted, or from the petit jury by which he is tried for the offense, resulting from systematic and arbitrary exclusion of blacks from the jury lists solely because of their race or color, is a denial of the equal protection under the Fourteenth Amendment. | |
Court membership | |
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Case opinion | |
Majority | Hughes, joined by Van Devanter, Cardozo, Brandeis, Butler, Sutherland, Roberts, Stone |
McReynolds took no part in the consideration or decision of the case. | |
Laws applied | |
U.S. Const. amend. XIV |
Norris v. Alabama, 294 U.S. 587 (1935), was one of the cases decided by the Supreme Court of the United States that arose out of the trial of the Scottsboro Boys, who were nine African-American teenagers falsely accused of raping two white women in 1931. The Scottsboro trial jury had no African-American members. Several cases were brought to the Supreme Court to debate the constitutionality of all-white juries. [1] Norris v. Alabama centered around Clarence Norris, one of the Scottsboro Boys, and his claim that the jury selection had systematically excluded black members due to racial prejudice. [2]
On April 1, 1935, an 8–0 Supreme Court decision authored by Chief Justice Charles Evans Hughes reversed the conviction of Clarence Norris on the grounds that evidence proved that African-Americans were unlawfully excluded from the jury. The lack of dissent characterizes the shift of national opinion on the ideas of race within the criminal justice system. [2] The Court's opinion states that though Alabama had no direct laws prohibiting African-American involvement in juries, its practices essentially accomplished this discrimination.
The Supreme Court held that the systematic exclusion of African Americans from jury service violated the Equal Protection Clause of the Fourteenth Amendment. The case was a significant advance in the Supreme Court's criminal procedure jurisprudence. Building on the existing precedent of Strauder v. West Virginia (1880) and Neal v. Delaware (1882), the Supreme Court addressed an Alabama statute that was facially neutral, but held that a criminal defendant could establish a prima facie (that is, accepted as true unless proven otherwise) claim of discrimination by showing that a substantial number of African Americans live in a community and that African Americans have been excluded from serving on juries. The prima facie evidence in this case was the disproportionality in the number of African-Americans who lived in the county compared to the number of African-Americans represented on juries.
Clarence Norris, though sentenced to death twice, died of old age in the year 1989. He was paroled in 1943 and pardoned by Alabama Governor George Wallace in 1976. He spent 15 years in prison and 30 years as a fugitive running from his parole. During this period as a runaway, Norris worked in New York as a warehouse employee. He was forced to change his name upon arrival because the stigma of being a Scottsboro Boy was too difficult to live with. [3] Also during his time in New York, Norris unsuccessfully fought for $10,000 in reparations for the injustices against him. [4] Though each of the Scottsboro Boys but the youngest received the death penalty, none of them was actually executed. [1] Clarence Norris was the last survivor out of the group of nine. [3]
The ultimate impact of the Norris v. Alabama case is its direct effect on how racial discrimination is viewed constitutionally. Prior to this judgment, all-white juries were commonplace and not considered unconstitutional. This Supreme Court opinion made racial diversity and proportionality an expectation in the courtroom. It relied upon the principles of the Fourteenth Amendment to the Constitution, the Equal Protection Clause, which states that the law should protect every American in an equal manner.
The Sixth Amendment to the United States Constitution sets forth rights related to criminal prosecutions. It was ratified in 1791 as part of the United States Bill of Rights. The Supreme Court has applied the protections of this amendment to the states through the Due Process Clause of the Fourteenth Amendment.
The Scottsboro Boys were nine African American teenagers, ages 13 to 20, accused in Alabama of raping two white women in 1931. The landmark set of legal cases from this incident dealt with racism and the right to a fair trial. The cases included a lynch mob before the suspects had been indicted, all-white juries, rushed trials, and disruptive mobs. It is commonly cited as an example of a miscarriage of justice in the United States legal system.
Batson v. Kentucky, 476 U.S. 79 (1986), was a landmark decision of the United States Supreme Court ruling that a prosecutor's use of a peremptory challenge in a criminal case—the dismissal of jurors without stating a valid cause for doing so—may not be used to exclude jurors based solely on their race. The Court ruled that this practice violated the Equal Protection Clause of the Fourteenth Amendment. The case gave rise to the term Batson challenge, an objection to a peremptory challenge based on the standard established by the Supreme Court's decision in this case. Subsequent jurisprudence has resulted in the extension of Batson to civil cases and cases where jurors are excluded on the basis of sex.
Powell v. Alabama, 287 U.S. 45 (1932), was a landmark United States Supreme Court decision in which the Court reversed the convictions of nine young black men for allegedly raping two white women on a freight train near Scottsboro, Alabama. The majority of the Court reasoned that the right to retain and be represented by a lawyer was fundamental to a fair trial and that at least in some circumstances, the trial judge must inform a defendant of this right. In addition, if the defendant cannot afford a lawyer, the court must appoint one sufficiently far in advance of trial to permit the lawyer to prepare adequately for the trial.
Strauder v. West Virginia, 100 U.S. 303 (1880), was a landmark decision of the Supreme Court of the United States about racial discrimination and United States constitutional criminal procedure. Strauder was the first instance where the Supreme Court reversed a state court decision denying a defendant's motion to remove his criminal trial to federal court pursuant to Section 3 of the Civil Rights Act of 1866.
Samuel Simon Leibowitz was a Romanian-American criminal defense attorney, famously noted for winning the vast majority of his cases, who later became a justice of the New York State Supreme Court.
Swain v. Alabama, 380 U.S. 202 (1965), was a case heard before the Supreme Court of the United States regarding the legality of a struck jury.
Whitus v. Georgia, 385 U.S. 545 (1967), found in favor of the petitioner (Whitus), who had been convicted for murder, and as such reversed their convictions. This was due to the Georgia jury selection policies, in which it was alleged racial discrimination had occurred.
Thomas E. Knight, Jr. was an American lawyer and politician who served as the 13th Lieutenant Governor of Alabama from 1935 to 1937, as well as the 19th Attorney General of Alabama from 1931 to 1935. He was a native of Greensboro, Alabama.
Edmonson v. Leesville Concrete Company, 500 U.S. 614 (1991), was a United States Supreme Court case which held that peremptory challenges may not be used to exclude jurors on the basis of race in civil trials. Edmonson extended the court's similar decision in Batson v. Kentucky (1986), a criminal case. The Court applied the equal protection component of the Due Process Clause of the Fifth Amendment, as determined in Bolling v. Sharpe (1954), in finding that such race-based challenges violated the Constitution.
Racial discrimination in jury selection is specifically prohibited by law in many jurisdictions throughout the world. In the United States it has been defined through a series of judicial decisions. However, juries composed solely of one racial group are legal in the United States and other countries. While the racial composition of juries is not dictated by law, racial discrimination in the selection of jurors is specifically prohibited. Depending on context, the phrases "all-white jury" or "all-black jury" can raise a host of expectations – among them, as MIT social neuroscientist Rebecca Saxe notes, the expectation that deliberations may be less than fair.
J. E. B. v. Alabama ex rel. T. B., 511 U.S. 127 (1994), was a landmark decision of the Supreme Court of the United States holding that peremptory challenges based solely on a prospective juror's sex are unconstitutional. J.E.B. extended the court's existing precedent in Batson v. Kentucky (1986), which found race-based peremptory challenges in criminal trials unconstitutional, and Edmonson v. Leesville Concrete Company (1991), which extended that principle to civil trials. As in Batson, the court found that sex-based challenges violate the Equal Protection Clause.
Hale v. Kentucky, 303 U.S. 613 (1938), was a United States Supreme Court case relating to racial discrimination in the selection of juries for criminal trials. The case overturned the conviction of an African American man accused of murder because the lower court of Kentucky had systematically excluded African Americans from serving on the jury in the case. NAACP counsel, including Charles H. Houston, Leon A. Ransom and Thurgood Marshall, represented Hale.
Bell v. Maryland, 378 U.S. 226 (1964), provided an opportunity for the Supreme Court of the United States to determine whether racial discrimination in the provision of public accommodations by a privately owned restaurant violated the Equal Protection and Due Process Clauses of the 14th Amendment to the United States Constitution. However, due to a supervening change in the state law, the Court vacated the judgment of the Maryland Court of Appeals and remanded the case to allow that court to determine whether the convictions for criminal trespass of twelve African American students should be dismissed.
Hernandez v. New York, 500 U.S. 352 (1991), was a decision by the United States Supreme Court, which held that a prosecutor may dismiss jurors who are bilingual in Spanish and English from juries that will consider Spanish-language testimony.
Hunter v. Underwood, 471 U.S. 222 (1985), was a case in which the United States Supreme Court, in a unanimous decision, invalidated the criminal disenfranchisement provision of § 182 of the Alabama Constitution as a violation of the Equal Protection Clause of the Fourteenth Amendment to the U.S. Constitution.
Vasquez v. Hillery, 474 U.S. 254 (1986), is a United States Supreme Court case, which held that a defendant's conviction must be reversed if members of their race were systematically excluded from the grand jury that indicted them, even if they were convicted following an otherwise fair trial.
Patterson v. Alabama, 294 U.S. 600 (1935), was a United States Supreme Court case which held that an African-American defendant is denied due process rights if the jury pool excludes African-Americans.
Davis v. Ayala, 576 U.S. 257 (2015), was a case in which the Supreme Court of the United States upheld a death sentence of a Hispanic defendant despite the fact that all Blacks and Hispanics were rejected from the jury during the defendant's trial. The case involved a habeas corpus petition submitted by Hector Ayala, who was arrested and tried in the late 1980s for the alleged murder of three individuals during an attempted robbery of an automobile body shop in San Diego, California in April 1985. At trial, the prosecution used peremptory challenges to strike all Black and Hispanic jurors who were available for jury service. The trial court judge allowed the prosecution to explain the basis for the peremptory challenges outside the presence of Ayala's counsel, "so as not to disclose trial strategy". Ayala was ultimately sentenced to death, but he filed several appeals challenging the constitutionality of the trial court's decision to exclude his counsel from the hearings.
Powers v. Ohio, 499 U.S. 400 (1991), was a United States Supreme Court case that re-examined the Batson Challenge. Established by Batson v. Kentucky, 476 U.S. 79 (1986), the Batson Challenge prohibits jury selectors from using peremptory challenges on the basis of race, ethnicity, gender, and sex. Powers expanded the jurisdictions of this principle, allowing all parties within a case, defendants especially, to question preemptory challenges during a jury selection, regardless of race. This holding was protected under the Equal Protection Clause of the Fourteenth Amendment.