McQuirter v. State

Brief Fact Summary. The Defendant, McQuirter (Defendant) a black man, was convicted of attempted rape. The Defendant was witnessed by a white woman following her down a road. After his arrest, the Defendant also allegedly confessed to the police that he intended to rape her.

Synopsis of Rule of Law. The element of intent is a question for the jury, who may consider social conditions and customs founded upon racial differences in determining whether a defendant intended to commit a particular crime.

Facts. A white woman observed the Defendant, a black man, following her down a road. The woman told her children to run to a neighbor’s house so that the neighbor, a man, could come and meet her. At the approach of the neighbor, the Defendant backed off and went back down the street until he came to the front of the woman’s home. The woman watched Defendant from her neighbor’s porch for thirty minutes, until Defendant finally walked away. A sheriff testified at trial that Defendant had confessed to intending to rape the woman, though Defendant disputed ever making such a statement.

Issue. Was the Defendant’s action in following woman, together with the statement he made to authorities, sufficient to convict him of intent to commit rape?

Held. Yes. Judgment affirmed.
On the evidence that Defendant confessed an intent to commit rape to the sheriff and was observed following a white woman down a road, a jury had a satisfactory basis upon which to find Defendant guilty of attempted rape. The jury could infer Defendant’s intent to rape the woman from “the social conditions and customs founded upon racial differences.” That is, if the jury believed that the black Defendant was in fact following the white woman, the purpose he had in doing so could reasonably be presumed to be rape.

Discussion. This case is notable insomuch as it seemed to permit social stereotypes about blacks to be used in drawing inferences about what Defendant’s intent was in following an unaccompanied white woman down the road.