Carter v. Texas

Background

Seth Carter, a Black man, was indicted in Galveston County, Texas, for the murder of Bertha Brantley in November 1897. Before he was arraigned, Carter filed a sworn motion to quash the indictment, alleging that the jury commissioners had excluded all persons of African descent from the grand jury because of their race, even though Black people made up about one fourth of the registered voters. The trial court overruled the motion without hearing evidence, Carter was convicted, and the Texas Court of Criminal Appeals affirmed the conviction and denied rehearing.

Reasoning

The Supreme Court addressed whether Carter’s federally protected right was violated when the state court refused to consider proof that Black people were excluded from the grand jury. Relying on prior decisions that exclusion of people of African descent from juries denies equal protection, the Court found that Carter had no chance to challenge the grand jury and properly raised the objection by motion. The record and bill of exceptions showed Carter offered to introduce witnesses but the trial court refused to hear any evidence. Because the state court’s assumption that no evidence was offered was contradicted by the record, the Supreme Court concluded Carter was denied his constitutional right and reversed the judgment.

Real world impact

The decision requires courts to consider and, where appropriate, allow proof when a defendant says jurors were excluded because of race. It protects defendants of African descent who lacked earlier opportunity to object to grand jury composition. The case was reversed and remanded for further proceedings consistent with the opinion.