Arnold v. North Carolina

Background

Arnold and Dixon, both Black men, were convicted of murder by a jury and their convictions were affirmed by the North Carolina Supreme Court. They had moved to quash the indictment, saying Black people were consistently left off the lists used to pick grand juries. They offered uncontradicted county records and clerk testimony showing many Black residents in the county but only one remembered Black person ever serving on a grand jury in 24 years; the State offered no contradictory evidence.

Reasoning

The core question was whether that evidence showed a systematic exclusion of Black people from the grand jury and thus violated equal protection. The Court treated the uncontradicted testimony as enough to make a prima facie case of discrimination, citing earlier decisions that found similar exclusions. Because the proof showed systematic exclusion, the Court concluded the convictions could not stand and ordered the judgment below reversed.

Real world impact

The decision means convictions based on indictments from grand juries shown to exclude Black residents can be overturned. It emphasizes that straightforward, uncontested evidence of racial exclusion is enough for courts to act. Prosecutors and local officials who rely on jury lists that omit Black residents may face new challenges in sustaining indictments and convictions when that exclusion is shown.