Norris v. Alabama

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Norris v. Alabama
Seal of the United States Supreme Court.svg
Argued February 15,18, 1935
Decided April 1, 1935
Full case nameNorris v. Alabama
Citations294 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
Chief Justice
Charles E. Hughes
Associate Justices
Willis Van Devanter  · James C. McReynolds
Louis Brandeis  · George Sutherland
Pierce Butler  · Harlan F. Stone
Owen Roberts  · Benjamin N. Cardozo
Case opinion
MajorityHughes, 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]

Contents

Clarence Norris

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]

Impact

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.

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Scottsboro Boys Nine [[African Americans|African American]] teenagers accused of rape in 1931

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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.

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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.

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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.

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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.

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References

  1. 1 2 "The Trials of "The Scottsboro Boys": An Account". famous-trials.com. Retrieved 2018-10-23.
  2. 1 2 "Norris v. Alabama - Oxford Reference" . Retrieved 2018-10-23.
  3. 1 2 Krebs, Albin. "Clarence Norris, The Last Survivor of 'Scottsboro Boys', Dies at 76" . Retrieved 2018-10-23.
  4. "Clarence Norris - National Registry of Exonerations Pre 1989". www.law.umich.edu. Retrieved 2018-10-23.