Lang v. New Jersey
Headline: Court upholds New Jersey rule limiting grand jurors by age and requiring challenges before swearing, ruling it does not violate equal protection and leaving the defendant’s murder conviction in place.
Holding: The Court held that New Jersey’s age limits for jurors and the rule barring objections after jurors are sworn do not violate the Fourteenth Amendment’s equal protection guarantee, so the conviction stands.
- Permits states to enforce juror age limits and timing for challenges.
- Makes it harder for defendants to challenge jurors after empanelment.
- Leaves convictions intact when objections are raised too late.
Summary
Background
A man convicted of murder in Middlesex County, New Jersey, challenged his indictment and conviction on equal protection grounds. The crime was committed after the grand jury had been impaneled, and two grand jurors were over the state’s age limit of sixty-five. He argued the statute was applied so that people accused after empanelment lose the chance to challenge unqualified jurors, creating unfair classes of defendants.
Reasoning
The Court reviewed the state statute that sets juror qualifications (citizen, county resident, age twenty-one to sixty-five) and bars exceptions after jurors are sworn. The New Jersey courts had held the rule aims to secure an efficient, representative grand jury and is not meant to benefit any particular class of accused persons. The Supreme Court agreed, finding no unconstitutional discrimination because the classification serves the legitimate purpose of producing an effective jury and does not deny substantial rights to defendants. The Court also noted that whether the statute’s phrase “any other disability” covers personal biases or common-law grounds was not presented or decided here.
Real world impact
The ruling leaves the conviction intact and upholds state power to set juror age rules and require timely objections. In practice, defendants must raise juror-qualification complaints before jurors are sworn or risk losing that challenge. The decision is narrow and does not resolve separate questions about personal bias or other individual juror faults.
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?