Floyd v. Garrison

Brief Fact Summary.

Floyd brought a civil rights case against a white officer and sought to have the jury dissolved because there was only one black juror in a pool of 40.

Synopsis of Rule of Law.

Selecting jurors from voter lists does not violate due process and the Jury Selection and Service Act if black people remain underrepresented in the jury pool unless there has been intentional discrimination or systematic exclusion.

Facts.

A black woman, Floyd, brought a civil rights suit against a white officer, Garrison, and requested that the jury pool be dissolved because there was only one black juror. Floyd’s motion was denied and the jury ruled for Garrison.

Issue.

Whether selecting jurors from voter lists violates due process and the Jury Selection and Service Act if black people remain underrepresented in the jury pool?

Held.

No. The judgment of the district court is affirmed. The fact that black people do not register to vote as often does not prove that there has been systematic exclusion from the juror pool. Similarly, an equal protection claim cannot be upheld because the percentage of black jurors in the pool is less than 4% below the representation of black jurors in the community.

Discussion.

The burden of proof is on the party asserting that jury selection is unfair and must prove: (1) black people are a distinct class within the community, (2) black people are not represented fairly in the jury pool in light of their presence in the community, and (3) the unfair representation of black people in juries is the result of the systematic exclusion of black people in the jury selection process.