Brief Fact Summary. A West Virginia statute limited jury service to white men. Strauder, a black man, was convicted of murder by a trial court in West Virginia.
Synopsis of Rule of Law. A citizen of the United States has a constitutional right to a criminal trial by jury selected and impaneled without discrimination against his race.
A right or an immunity, whether created by the Constitution or only guaranteed by it, even without any express delegation of power, may be protected by Congress.View Full Point of Law
Issue. Did Strauder’s conviction by a jury selected pursuant to the statute violate the Fourteenth Amendment of the United States Constitution (Constitution)?
Held. Yes. The judgments of the Supreme Court of West Virginia and the Circuit Court of Ohio County are reversed.
Justice William Strong said the Fourteenth Amendment of the Constitution gave to blacks the right to be free from unfriendly legislation directed at them on the basis of their race. The West Virginia statute concerning juries is the quintessential legislation the Fourteenth Amendment of the Constitution was designed to prohibit. The fact that blacks as such are singled out and expressly denied by statute the right to participate in the administration of justice, as jurors, places a brand upon them and impedes their ability to secure the equal justice the law aims to secure for all others.
Discussion. This is an early case in which the Supreme Court of the United States (Supreme Court) subjects a state government to a standard of review more rigorous than the rational basis test.