Summary
The Supreme Court held that Rodrigo Partida established a prima facie case of purposeful discrimination against Mexican-Americans in the selection of Hidalgo County, Texas, grand juries. The statistical disparity and the subjective nature of Texas's key-man selection system shifted the burden to the State to rebut the inference of discrimination. The State's evidence, including the theory that Mexican-Americans held a governing majority in the county, was insufficient, so the Court affirmed the finding of an equal protection violation.
Topics
Practice areas
Questions Presented
- Whether Partida established a prima facie case of purposeful discrimination in the selection of Hidalgo County grand jurors through evidence of substantial underrepresentation, the composition of the identifiable class, and the subjective selection procedure.
- Whether the State rebutted the prima facie case by showing that neutral selection criteria or procedures produced the disparity.
- Whether the presence of a Mexican-American governing majority in Hidalgo County rebutted the inference of purposeful discrimination.
Holdings
- A defendant establishes a prima facie case of purposeful discrimination in grand-jury selection by showing that a recognizable, distinct class was substantially underrepresented over a significant period and that the selection procedure was susceptible to abuse or was not racially neutral. Partida's evidence satisfied that standard.
- Once a defendant establishes substantial underrepresentation and a prima facie case of purposeful discrimination, the burden shifts to the State to rebut the inference with competent evidence concerning neutral selection criteria, procedures, and the actual operation of the selection process. The State failed to do so here.
- The existence of a governing majority belonging to the same ethnic group as the allegedly underrepresented class does not, by itself, rebut a prima facie case of purposeful discrimination in grand-jury selection.
Key quotations
“Thus, in order to show that an equal protection violation has occurred in the context of grand jury selection, the defendant must show that the procedure employed resulted in substantial underrepresentation of his race or of the identifiable group to which he belongs.” (494)
“Once the defendant has shown substantial underrepresentation of his group, he has made out a prima facie case of discriminatory purpose, and the burden then shifts to the State to rebut that case.” (495)
“Without the benefit of this simple behavioral presumption, discriminatory intent can be rebutted only with evidence in the record about the way in which the commissioners operated and their reasons for doing so.” (500)
“Since the State failed to rebut the presumption of purposeful discrimination by competent testimony, despite two opportunities to do so, we affirm the Court of Appeals' holding of a denial of equal protection of the law in the grand jury selection process in respondent's case.” (501)
Factual background
Partida, a Mexican-American, was indicted in March 1972 by a Hidalgo County grand jury for burglary of a private residence at night with intent to rape. Mexican-Americans constituted approximately 79.1% of Hidalgo County's population, but Spanish-surnamed persons constituted only 39% of those summoned for grand jury service over an eleven-year period. Texas used a discretionary "key man" system in which jury commissioners selected prospective grand jurors, and the State offered little evidence to explain the substantial disparity or the operation of the selection process.
Procedural history
Partida was indicted and convicted in Texas state court and raised his grand-jury discrimination claim in a motion for new trial. The Texas Court of Criminal Appeals affirmed, concluding that he had not established a prima facie case. The United States District Court for the Southern District of Texas dismissed his federal habeas petition, but the Fifth Circuit reversed. The Supreme Court granted certiorari and affirmed the Fifth Circuit.