Hale v. Kentucky

Background

A Black man was indicted for murder in McCracken County, Kentucky, in 1936. He asked the trial court to throw out the indictment because the county’s jury commissioners had filled the jury wheel with 500–600 names made up entirely of white citizens. Affidavits showed the county had many qualified Black residents, local sheriffs said no Black person had been summoned to state juries from 1906 to 1936, and federal court records showed Black jurors had served there. The State agreed the affidavits could be treated as evidence and introduced no contradictory proof. The trial court denied the motions, the defendant was convicted and sentenced to death, and the state courts affirmed before the case reached this Court.

Reasoning

The Court considered whether the uncontroverted affidavits proved a long, systematic exclusion of Black citizens from jury service solely because of race. Relying on prior decisions, the Court concluded the evidence did show arbitrary, race-based exclusion that denied the defendant equal protection under the Fourteenth Amendment. Because the State stipulated the affidavits as proof and offered no opposing evidence, the Court found the denial of equal protection clear and reversed the conviction.

Real world impact

The decision prevents counties from using jury lists that systematically exclude Black citizens for reasons of race. It requires courts to treat uncontradicted proof of racial exclusion as violating constitutional equal protection and sends cases back for further proceedings consistent with that ruling.