Norris v. Alabama

Background

Clarence Norris, one of nine Black youths indicted for rape in Jackson County, Alabama, was retried after an earlier reversal for lack of counsel. After a change of venue, he was tried in Morgan County, convicted, and sentenced to death. Norris moved to quash the indictment and the trial jury list, saying Black residents had been systematically excluded from juries in both counties. State courts denied those motions and affirmed the conviction, and the case came to this Court for review of the federal equal-protection claim.

Reasoning

The core question was whether the longstanding practice of excluding Black people from juries denied equal treatment under the Constitution. The Court examined the state record closely. It relied on population figures, eyewitness testimony that no Black person had served on juries for decades, evidence of many qualified Black citizens who were never placed on jury rolls, and suspicious jury-roll entries. The officials’ general denials did not rebut this proof. The Court concluded the evidence established systematic racial exclusion in both Jackson and Morgan Counties and that the exclusion denied Norris his constitutional right.

Real world impact

Because the Court found unconstitutional discrimination, it reversed the conviction and sent the case back for further proceedings consistent with that ruling. The decision means jury-selection practices that keep qualified Black residents off juries cannot stand. Trials in those counties and similar situations must confront and correct such exclusion before convictions can be enforced.

Dissents or concurrances

No justice wrote a dissent; Justice McReynolds did not participate in the argument or decision.