Patton v. Mississippi

Background

A Black man was indicted by an all-white grand jury, convicted by an all-white trial jury, and sentenced to death in Lauderdale County, Mississippi. He moved to dismiss the indictment because no Black names appeared on the jury lists, and the record showed that no Black person had served on criminal juries there for thirty years or more. The State argued that so few Black men were eligible electors under state rules that their absence from a single venire was unsurprising.

Reasoning

The Court asked whether the long, complete absence of Black jurors showed systematic racial exclusion that violates the Fourteenth Amendment’s promise of equal protection. Relying on earlier decisions, the Court said the uncontradicted fact of decades without any Black juror created a strong showing of purposeful discrimination. That shifted the burden to the State to explain a race-neutral reason. The state courts focused only on a single jury panel and used percentage math instead of confronting the thirty-year exclusion. The State offered no satisfactory nonracial justification, so the Court concluded the selection practice denied equal protection and reversed the conviction.

Real world impact

The decision means indictments and verdicts returned by juries formed after a long, race-based exclusion cannot stand. States must ensure jury lists and selection practices do not systematically exclude racial groups, and convictions obtained by such juries may be overturned or retried with properly selected juries. The case was sent back to the lower court for further proceedings consistent with this ruling.