Floyd v. Garrison

Brief Fact Summary.

Plaintiff moved to dismiss the jury pool and then moved for a new trial on the grounds that selecting prospective jurors from a voter registration list resulted in the underrepresentation of black jurors, violating the Jury Selection and Service Act of 1968 and the Fifth Amendment.

Synopsis of Rule of Law.

Selecting prospective jurors from a voter registration list does not violate the Jury Selection and Service Act of 1968 and the Fifth Amendment, unless the moving party can sufficiently demonstrate systemic or intentional racial discrimination.

Facts.

Mattie Ruth Floyd (Plaintiff), a black woman, sued Marty Garrison (Defendant), a white police officer, for unreasonable and unlawful deadly force after he shot and killed Jason L.C. Floyd. Only one of the prospective forty jurors was black. Plaintiff moved to dissolve the jury pool before trial and moved for a new trial after the jury found for Defendant, on the grounds that selecting prospective jurors from a voter registration list violated the Jury Selection and Service Act of 1968 and the Fifth Amendment.

Issue.

Is the underrepresentation of black jurors, selected from a voter registration list, a violation of Jury Selection and Service Act of 1968 and the Fifth Amendment?

Held.

No, without a showing of intentional and systemic discrimination the use of voter registration lists is consistent with the Jury Selection and Service Act of 1968 and the Fifth Amendment. The lower court is affirmed.

Discussion.

The Court determined that the use of voter registration lists did not violate the Jury Selection and Service Act of 1968 in this case because Plaintiff did not establish a prima facie case of discrimination in the selection of jurors from the community. The Court found the Plaintiff’s evidence that black individuals did not register to vote as often as other citizens insufficient to establish that the underrepresentation in the jury selection was due to the systemic exclusion of blacks from the selection process. Additionally, the Court determined that the use of voter registration lists did not violate the Fifth Amendment because Plaintiff failed to establish a prima facie violation of equal protection. The Court found no evidence of intentional discrimination in the random selection of jurors off of the voter registration lists.