Strauder v. West Virginia
Encyclopedia
Strauder v. West Virginia, , was a United States Supreme Court
case about racial discrimination.
excluded African-Americans from juries
. Strauder was a Black man who, at trial, had been convicted of murder by an all-white jury. Strauder appeal
ed his conviction, contending that West Virginia exclusionary policy violated the Equal Protection Clause
of the Fourteenth Amendment
to the United States Constitution
.
, held that categorical exclusion of blacks from juries for no other reason than their race did indeed violate the Equal Protection Clause, since the very purpose of the Clause was "to assure to the colored race the enjoyment of all the civil rights that under the law are enjoyed by white persons, and to give to that race the protection of the general government, in that enjoyment, whenever it should be denied by the States." The Court did not say that exclusion of blacks from juries violated the rights of potential jury members; rather, such exclusion violated the rights of black criminal defendants, since juries would be "drawn from a panel from which the State has expressly excluded every man of [a defendant's] race."
The Court did not hold that any particular jury must be racially balanced in order to satisfy equal protection; the categorical exclusion from all juries was the problem. This holding is reaffirmed in the important 20th-century equal protection case Washington v. Davis
: "[Strauder] established that the exclusion" of African-Americans from juries violates equal protection, but if a particular jury or series of juries "does not statistically reflect the racial composition of the community does not in itself make out an invidious discrimination forbidden by the Clause
While a victory for the rights of black defendants and an important early civil rights case, Strauder v. West Virginia upheld the right of states to bar women or other classes from juries, holding, in the words of Justice Strong, that a state "may confine the selection to males, to freeholders, to citizens, to persons within certain ages, or to persons having educational qualifications. We do not believe the Fourteenth Amendment was ever intended to prohibit this. ... Its aim was against discrimination because of race or color." The precedent set by Strauder has continued to influence rulings in cases as late as 1961 in Hoyt v. Florida
, 368 U.S. 57 (1961)
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case about racial discrimination.
Background
At the time, West VirginiaWest Virginia
West Virginia is a state in the Appalachian and Southeastern regions of the United States, bordered by Virginia to the southeast, Kentucky to the southwest, Ohio to the northwest, Pennsylvania to the northeast and Maryland to the east...
excluded African-Americans from juries
Jury
A jury is a sworn body of people convened to render an impartial verdict officially submitted to them by a court, or to set a penalty or judgment. Modern juries tend to be found in courts to ascertain the guilt, or lack thereof, in a crime. In Anglophone jurisdictions, the verdict may be guilty,...
. Strauder was a Black man who, at trial, had been convicted of murder by an all-white jury. Strauder appeal
Appeal
An appeal is a petition for review of a case that has been decided by a court of law. The petition is made to a higher court for the purpose of overturning the lower court's decision....
ed his conviction, contending that West Virginia exclusionary policy violated the Equal Protection Clause
Equal Protection Clause
The Equal Protection Clause, part of the Fourteenth Amendment to the United States Constitution, provides that "no state shall ... deny to any person within its jurisdiction the equal protection of the laws"...
of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
to the United States Constitution
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
.
Opinion of the Court
The majority, speaking through Justice William StrongWilliam Strong (judge)
William Strong was an American jurist and politician. He was a justice on the Supreme Court of Pennsylvania and an Associate Justice on the Supreme Court of the United States.-Early life:...
, held that categorical exclusion of blacks from juries for no other reason than their race did indeed violate the Equal Protection Clause, since the very purpose of the Clause was "to assure to the colored race the enjoyment of all the civil rights that under the law are enjoyed by white persons, and to give to that race the protection of the general government, in that enjoyment, whenever it should be denied by the States." The Court did not say that exclusion of blacks from juries violated the rights of potential jury members; rather, such exclusion violated the rights of black criminal defendants, since juries would be "drawn from a panel from which the State has expressly excluded every man of [a defendant's] race."
The Court did not hold that any particular jury must be racially balanced in order to satisfy equal protection; the categorical exclusion from all juries was the problem. This holding is reaffirmed in the important 20th-century equal protection case Washington v. Davis
Washington v. Davis
Washington v. Davis, , was a United States Supreme Court case regarding the application of the Due Process Clause. Two African Americans had applied for positions in the Washington, DC police department, and sued after being turned down...
: "[Strauder] established that the exclusion" of African-Americans from juries violates equal protection, but if a particular jury or series of juries "does not statistically reflect the racial composition of the community does not in itself make out an invidious discrimination forbidden by the Clause
While a victory for the rights of black defendants and an important early civil rights case, Strauder v. West Virginia upheld the right of states to bar women or other classes from juries, holding, in the words of Justice Strong, that a state "may confine the selection to males, to freeholders, to citizens, to persons within certain ages, or to persons having educational qualifications. We do not believe the Fourteenth Amendment was ever intended to prohibit this. ... Its aim was against discrimination because of race or color." The precedent set by Strauder has continued to influence rulings in cases as late as 1961 in Hoyt v. Florida
Hoyt v. Florida
Hoyt v. Florida, 368 U.S. 57 , was an appeal by Gwendolyn Hoyt, who had killed her husband and received a jail sentence for second degree murder...
, 368 U.S. 57 (1961)