Hill v. Texas

Background

A Black man was indicted for rape in Dallas County, Texas. Before trial he asked the court to throw out the indictment, saying county officials had long excluded Black people from grand juries and denied him equal treatment. At trial the court rejected that claim and he was convicted. The Texas Court of Criminal Appeals upheld the conviction, finding the defendant had not proved racial exclusion rather than lack of qualifications, so the case went to this Court.

Reasoning

The main question was whether the county’s long failure to summon Black people to grand juries violated the Constitution’s guarantee of equal treatment. The Court reviewed testimony that commissioners only named white men they knew, made no effort to discover qualified Black candidates, and that many Black residents were literate, owned property, and paid poll taxes. Because the State presented no evidence to contradict these facts, the Court found the defendant had shown enough to infer racial discrimination, relied on earlier decisions facing similar facts, and held that convictions obtained after such exclusion cannot stand.

Real world impact

The decision means counties must not systematically exclude Black residents when forming grand juries and must take steps to identify qualified Black citizens. Convictions based on grand juries drawn after such exclusion must be overturned, though the State may try the defendant again with a properly selected grand jury. The ruling enforces equal treatment in jury selection and prevents officials from relying on ignorance or habit to avoid including Black jurors.