Edmonson v. Leesville Concrete Company, Inc

Brief Fact Summary. The Plaintiff, Edmonson (Plaintiff), appealed the jury decision in his negligence suit citing the Defendant, Leesville Concrete Company’s (Defendant), use of race-based peremptory challenges.
Synopsis of Rule of Law. Peremptory challenges cannot be used to exclude prospective jurors based on reasons of race.

Facts. Plaintiff was a construction worker who was injured on a federal jobsite. He sued the Defendant in the United States District Court for the Western District of Louisiana for negligence, claiming that one of Defendant’s employees allowed a truck to roll backwards and pin the Plaintiff to another piece of equipment. Plaintiff asked for a jury trial. During voire dire, the Defendant challenged two jurors on account of their race. Plaintiff, also black, asked the court to express a race-neutral explanation for striking the two jurors, which the court declined. The final jury consisted of 11 white members and one black member. The jury found for the Plaintiff in the amount of $80,000 but the award was reduced due to Plaintiff’s contributory negligence and totaled $18,000. The Court of Appeals affirmed.

Issue. Whether a private litigant in a civil case may use peremptory challenges to exclude jurors on account of their race.

Held. Recognizing the impropriety of racial bias in the courtroom, race-based exclusion violates the equal protection rights of the challenged jurors. Judgment reversed and case remanded for further proceedings consistent with this opinion.

Dissent. United States Supreme Court Justices Sandra Day O’Connor (J. O’Connor), Chief Justice William Rehnquist (J. Rehnquist) and Antonin Scalia (J. Scalia) dissented and argued that whatever reasons a private litigant may have for using a peremptory challenge, it is not the government’s reason or responsibility.

Discussion. The United States Constitution’s (Constitution) protections of individual liberty and equal protection apply in general only to action by the government. Racial discrimination violates the Constitution only when it may be subject to the Constitution’s restrictions. When private litigants participate in the selection of jurors, they serve an important function within the government and act with its assistance. If peremptory challenges based on race were permitted, persons could be required by summons to be at risk of open and public discrimination as a condition of their participation in the justice system, hence, as a direct result of government participation. The injury caused by discrimination is more severe when the government allows it to happen within the courthouse itself. To permit racial exclusion in this official forum compounds the racial insult inherent in judging a citizen by the color of his or her skin. Establishing a prima facie case of race-based peremptory challenges requires consideration of all relevant circumstances, including whether there has been a pattern of strikes against members of a particular race. This approach applies in the civil context as well.