Alexander v. Louisiana

Background

A Black man was tried for rape in Lafayette Parish, Louisiana, convicted by a 12-member jury, and sentenced to life. Before trial he asked the court to throw out the indictment because Black citizens were present in only token numbers at each stage of grand jury selection and because women were largely excluded. The record included local census and jury-list evidence and described how questionnaires and information cards were used to create the jury pool.

Reasoning

The Court examined how the pool of potential jurors shrank at each step: about 21% of adults were Black, 14% of returned questionnaires were from Black people, 6.75% of the 400-person list were Black, one person on the 20-person venire was Black, and none on the grand jury that indicted him were Black. The forms used identified race, so the selection process provided an opportunity for discrimination. The Court found a prima facie case of racial discrimination and concluded the State did not adequately show neutral procedures produced the result, so the indictment and conviction could not stand.

Real world impact

The decision invalidates indictments where jury-selection methods create clear racial disparities and where the State cannot explain them. It places a burden on local officials to use selection practices that do not permit race-based exclusion. The ruling does not permanently resolve every issue: the State may refile charges and must use a properly selected grand jury.

Dissents or concurrances

A concurring Justice said the Court should also have ruled that Louisiana’s statute that effectively excluded women from jury rolls was unconstitutional, but the majority avoided that question.