Campbell v. Louisiana

1998-04-21

Headline: White defendant gains right to challenge racial exclusion from grand jury selection as Court reverses state ruling, allowing review of judge-appointed foreperson practices that shape who serves and how indictments are made.

Holding: The Court held that a white criminal defendant has standing to challenge racial discrimination in grand jury selection, allowing him to raise equal protection and due process claims and sending the case back for further proceedings.

Real World Impact:

Allows defendants to challenge racial exclusion in grand jury selection.
May prompt hearings into judge-appointed foreperson practices.
Could require courts to review grand jury appointment procedures.

Topics: racial discrimination, grand jury selection, jury rights, defendant standing to sue, due process

Summary

Background

A white man in Evangeline Parish, Louisiana, was indicted for second-degree murder and challenged the grand jury that returned the indictment. He alleged a long practice of racial exclusion: between January 1976 and August 1993 no Black person served as grand jury foreperson, even though over 20% of registered voters were Black. State courts disagreed about whether he could raise those complaints, and his case reached this Court on the narrow question of standing to sue.

Reasoning

The Court asked whether a white criminal defendant can object when Black people are excluded from grand jury service. It said yes: applying the logic of Powers v. Ohio, the defendant met the three preconditions for raising others’ equal protection claims. The Court stressed that Louisiana’s method—where the judge picks a foreperson from the venire before the rest are chosen by lot and the foreperson has full voting power—can change the grand jury’s composition. The Court rejected the state court’s reliance on Hobby, explaining Hobby did not address a system that alters grand jury membership.

Real world impact

The ruling reverses the Louisiana Supreme Court and sends the case back for further proceedings. Criminal defendants may now be able to challenge racially biased grand jury appointment practices, and judges and prosecutors may face hearings or evidence demands about how forepersons and jurors are chosen. This decision addresses standing, not the final merits, so the ultimate outcome can still change on remand.

Dissents or concurrances

Justice Thomas (joined by Justice Scalia) agreed with most of the judgment but dissented from the part granting third-party standing, arguing Powers was wrongly decided and should not apply here.