Summary
The Supreme Court held that the systematic exclusion of persons of Mexican descent from jury service in Jackson County, Texas, violated the Equal Protection Clause of the Fourteenth Amendment. The Court concluded that Mexican Americans constituted a distinct class in the community and that the prolonged absence of eligible persons of Mexican descent from jury commissions, grand juries, and petit juries established discrimination. The conviction was reversed.
Topics
Practice areas
Questions Presented
- Whether the systematic exclusion of persons of Mexican descent from jury commissions, grand juries, and petit juries violated the Equal Protection Clause of the Fourteenth Amendment.
- Whether the Fourteenth Amendment protects a distinct class defined by ancestry or national origin, even when the class is not limited to the traditional categories of white and Negro.
- Whether the evidence established a prima facie case of systematic exclusion that was not overcome by general denials of discrimination from jury commissioners.
Holdings
- The Equal Protection Clause prohibits the exclusion of otherwise eligible persons from jury service solely because of their ancestry or national origin, and this protection extends to distinct classes other than the traditional categories of white and Negro.
- Hernandez established a prima facie case of systematic exclusion by showing a substantial eligible Mexican-American population and the complete absence of persons of Mexican or Latin-American descent from jury service for twenty-five years; general assertions by jury commissioners that they had not discriminated were insufficient to rebut that showing.
- The decision does not require proportional representation of all ethnic groups on every jury; it requires that juries be selected from among all qualified persons without systematic exclusion based on national origin or ancestry.
Key quotations
“When the existence of a distinct class is demonstrated, and it is further shown that the laws, as written or as applied, single out that class for different treatment not based on some reasonable classification, the guarantees of the Constitution have been violated.” (at 478-479)
“The exclusion of otherwise eligible persons from jury service solely because of their ancestry or national origin is discrimination prohibited by the Fourteenth Amendment.” (at 479)
“His only claim is the right to be indicted and tried by juries from which all members of his class are not systematically excluded— juries selected from among all qualified persons regardless of national origin or descent.” (at 482)
Factual background
Hernandez, a person of Mexican descent, was tried for murder in Jackson County, Texas. Evidence showed that persons of Mexican descent constituted a distinct community class in the county, including evidence of social segregation, discriminatory signs, and limited participation in community organizations. The State stipulated that for twenty-five years no person with a Mexican or Latin-American name had served on a jury commission, grand jury, or petit jury in the county, despite the presence of eligible persons of Mexican descent.
Procedural history
Hernandez was indicted for murder in Jackson County, Texas, convicted, and sentenced to life imprisonment. Before and during trial, he moved to quash the indictment and jury panel, alleging that persons of Mexican descent had been systematically excluded from jury commissions, grand juries, and petit juries. The trial court denied the motions, and the Texas Court of Criminal Appeals affirmed. The Supreme Court granted certiorari and reversed.