Lynn v. Alabama

Background

Frederick Lynn, an Afro-American man, was convicted of murder by an all-white jury in Barbour County, Alabama, and sentenced to death. During jury selection, the prosecutor used 11 of 14 peremptory strikes to remove all potential Black jurors. The county has roughly equal white and Black populations, and certain neighborhoods are mostly people of color; two challenged jurors lived on the same road as the defendant’s relatives.

Reasoning

The Supreme Court declined to review the case, leaving the state-court conviction and death sentence in place. Before the denial, a lower court held a hearing under Batson (the rule against race-based juror exclusion) and found the prosecutor’s neighborhood-based explanations sufficient to rebut a claim of racial discrimination; the Alabama Court of Criminal Appeals affirmed that finding. The central factual issue is whether relying on a nonracial factor that closely tracks race—like where someone lives—can be a legitimate reason to strike jurors without further questioning.

Real world impact

Because the Court denied review, the death sentence stands and the broader question about using residence as a proxy for race in jury selection remains unresolved at the national level. The decision affects defendants in small, racially segregated communities where address and race are closely linked, and it leaves in place a trial record in which prosecutors justified strikes by pointing to neighborhood ties rather than direct evidence of bias.

Dissents or concurrances

Justice Marshall, joined by Justice Brennan, dissented and would have granted review and vacated the sentence, arguing that uncorroborated residence-based strikes are an unlawful proxy for race and undermine Batson’s protections.