Edmonson v. Leesville Concrete, Inc.

Brief Fact Summary.

Plaintiff sued Defendant for negligence after he was injured on their worksite. Defendant used peremptory challenges to remove two Black persons from the jury during voir dire, and the Plaintiff moved to require the Defendant to state a race-neutral reason for the removals.

Synopsis of Rule of Law.

Under the Due Process Clause of the Fifth Amendment, a private litigant in a civil case cannot use peremptory challenges to exclude prospective jurors on the basis of race.

Facts.

Thaddeus Donald Edmonson (Plaintiff), a black construction worker, sued Leesville Concrete Co. (Defendant) for negligence after he was injured while working on their construction site. During voir dire, Defendant used two peremptory challenges to remove Black persons from the prospective jury. Plaintiff, relying on Batson, requested that the court require Defendant to articulate a race-neutral reason for its peremptory challenges.

Issue.

May a private litigant in a civil proceeding use peremptory challenges to exclude jurors on the basis of race?

Held.

No, peremptory challenges on the basis of race in civil proceedings are a violation of equal protection. The lower court’s decision is reversed and remanded.

Dissent.

Justice O’Connor

Justice O’Connor disagreed with the Court’s interpretation of government action in the courtroom, and argued that a peremptory challenge brought by a private litigant is a private action. These private actions are not governed by the Fifth Amendment.

Justice Scalia

Justice Scalia argued that the Court’s rule would harm minority litigants in criminal proceedings and burden the court with an enormous increase of time and effort put towards Batson Challenges in all civil jury cases.

Discussion.

The Court determined that the jury selection process, including voir dire and peremptory challenges, were considered acts of the government because it is controlled significantly by the trial court and thus subject to constitutional constraints. Under the Due Process Clause of the Fifth Amendment, even the private litigant in a civil case cannot use peremptory challenges to exclude prospective jurors on the basis of race. On remand, the Court ordered the lower court to determined whether there was a prima facie case of race discrimination under Batson.