Edmonson v. Leesville Concrete Co.

Brief Fact Summary.

A Black man sues his company after he is injured on the job and requests a jury trial. During jury selection the Defendant uses peremptory challenges to remove Black juror from the prospective jury for no reason. Plaintiff Edmonson requested the court to require the Defendant to state non-racial reasons for removing the prospective jurors, but the court denies the request.

Synopsis of Rule of Law.

A private litigant in a civil case may not use peremptory challenges to exclude jurors on account of their race because the exercise of peremptory challenges involves state action.

Facts.

Plaintiff Edmonson sues Defendant Leesville Concrete for negligence in Federal District court after he is injured on the job. Plaintiff Edmonson requested a jury trial under the Seventh Amendment. During voir dire Defendant Leesville used two of its three statutorily permitted peremptory challenges to remove Black people from the jury pool. Plaintiff Edmonson was also Black. Plaintiff Edmonson requested that the court require Defendant Leesville to state non-racial reasons for its peremptory challenges of the prospective jurors. The court denied the request based on the fact the case was a civil case. The final jury consisted of 11 white people and one Black person. The jury found in favor of Plaintiff Edmonson and awarded $90,000 in damages, but reduced it to $18,000, finding Plaintiff Edmonson to be 80% at fault. Plaintiff Edmonson appealed and the Court of Appeals for the Fifth Circuit affirmed. The Supreme Court of the United States granted certiorari.

Issue.

May a private litigant in a civil case use peremptory challenges to exclude jurors because of their race?

Held.

No, a private litigant cannot use peremptory challenges to exclude jurors because of their race. Decision of the court of appeals is reversed.

Dissent.

Justice Justice O’Connor joined by Chief Justice Rehnquist and Justice Scalia dissenting

Omitted.

Justice Justice Scalia dissenting

Omitted.

Concurrence.

Justice Justice Scalia dissenting

Omitted.

Discussion.

1. If there is a finding of action, Defendant Leesville’s actions can be overturned based on the Fourtheenth Amendment’s prohibition of race-based discrimination.
2. Under the Lugar v. Edmonson Oil analysis, Leesville acted according to state authority.
3. Exercising a peremptory challenge is grounded in state authority.
4. A peremptory challenge is occurring with a state sanctioned court of law.
5. Also, a peremptory challenge may only be used based on statutory authority provided by the government.
6. Second, Leesville can be considered a government actor because precedent has found a private party to be a state actor when the party makes extensive use of state procedures with the over, significant assistance of state officials.
7. The judge, unequivocally a state actor, enforced Defendant Leesville’s peremptory challenges and finalized the denial of the jurors to serve on the jury.
8. Therefore, Defendant Leesville acted pursuant to state authority and the discriminatory peremptory challenges are prohibited by the Fourteenth Amendment.
9. The decision of the court of appeals is reversed.