Lang v. New Jersey
The Court upheld a New Jersey murder conviction, rejecting the defendant's argument that a state jury-age rule denied him equal protection because he had no chance to challenge a grand juror over 65 before it was sworn.
The ruling confirms that states can set practical cutoffs for objecting to jurors' qualifications without violating the Fourteenth Amendment, so long as the rule serves the efficient administration of justice rather than favoring one class of defendants over another.
“We think it is competent for the State to have so provided.”
The Court's conclusion that New Jersey could set a cutoff date for juror-qualification challenges.
How it got here: A New Jersey trial court denied the defendant's motion to quash the indictment; the state supreme court and court of errors and appeals affirmed, and he sought review in the U.S. Supreme Court.
The Case in Depth
What happened
A New Jersey man was convicted of murder by a grand jury that included two members over the state's 65-year age limit for jurors. Because his crime occurred after the grand jury had already been sworn in, he had no opportunity to object to those jurors' ages before the deadline the state's jury statute set for such challenges.
The question before the Court
Could New Jersey require a murder defendant to challenge an over-age grand juror before the jury was sworn, even though his crime happened after the jury was already impaneled?
Why it matters
The decision lets states enforce firm deadlines for challenging jurors' qualifications, even when a crime happens after the jury is already sworn in. It signals that procedural cutoffs tied to efficient court administration, rather than favoritism toward defendants, generally survive equal protection challenges.
What changes now
This is a final decision on the merits, so the murder conviction stands as affirmed by the New Jersey courts. The Court did not address whether the same reasoning would apply to challenges based on a juror's personal bias or prejudice discovered after swearing-in, leaving that question for a future case if one arises.
What this does not decide
The Court expressly declined to decide whether the statute's phrase "any other legal disability" covers common-law grounds like a juror's personal prejudice or malice, or what remedies a defendant would have if denied a chance to challenge a juror on those grounds. That question was left open for another case.
Concurrences and dissents
How the Justices voted
Majority (1). Justice McKenna (author).
How the Court got there
The legal reasoning, step by step
- The Court accepted the New Jersey Court of Errors and Appeals' reading that the jury-age statute exists to make grand juries efficient and representative for the benefit of the public generally, not as a personal protection for people who might later be charged with crimes.
- Because equal protection only requires that a classification serve a legitimate purpose, the Court asked whether people accused before an indictment and those accused afterward stand in different relations to that purpose, and concluded they do, since the rule's practical cutoff for challenges applies to the process, not to any particular defendant.
- The Court found the requirement that objections be raised before the grand jury is sworn to be a reasonable practical measure, noting that prosecutors, accused persons, and even outside parties could raise such objections during that window.
- The Court noted that the defendant could not show any actual prejudice from an over-age juror's presence, and treated any resulting discrimination between the two classes of defendants as insubstantial.
- Applying these conclusions, the Court held that the statute, as construed by the state courts, created no unconstitutional discrimination between classes of defendants.