Legal Definitions - Norris v. Alabama (1935)

Norris v. Alabama (1935) is a landmark United States Supreme Court case that significantly impacted the legal principle of fair jury selection, particularly concerning racial discrimination.

The case arose from the trials of the "Scottsboro Boys," nine African-American men falsely accused of rape in Alabama. The Supreme Court's decision in Norris v. Alabama overturned the conviction of Clarence Norris, one of the defendants. The Court found that the systematic exclusion of African Americans from jury service in the counties where Norris was indicted and tried violated his rights under the Fourteenth Amendment of the U.S. Constitution, which guarantees both due process and equal protection under the law.

The Court held that even if a state's jury selection laws appeared neutral on their face, a "long continued, systematic and arbitrary exclusion" of a particular racial group from jury panels constituted unconstitutional discrimination. This ruling established that a defendant could present evidence of such historical exclusion to make a "prima facie case" (meaning, sufficient evidence to establish a fact or raise a presumption unless disproved or rebutted) of discrimination, shifting the burden to the state to prove that the exclusion was not discriminatory.

Here are some examples illustrating the principles established in Norris v. Alabama:

• Example 1: Challenging Jury Composition in a Modern Trial

  Imagine a criminal trial in a rural county where the population is 25% Hispanic. A defendant, who is Hispanic, notices that over the past decade, no Hispanic individuals have ever served on a jury in that county, despite many being eligible. The defense team could invoke the precedent of Norris v. Alabama to challenge the jury selection process. They would argue that this consistent absence demonstrates a "systematic and arbitrary exclusion" of Hispanic individuals from jury service, violating the defendant's right to equal protection and a fair trial, even if the written jury selection rules appear race-neutral.

• Example 2: Statistical Evidence of Exclusion

  A civil rights organization conducts a study of jury selection practices in a particular state. Their research reveals that in several counties, while the eligible African-American population constitutes 30% of residents, African Americans make up less than 5% of individuals called for jury duty over a 20-year period. This significant statistical disparity, showing a consistent underrepresentation, could be used by a defendant in a subsequent trial to argue that the county's jury selection process systematically excludes African Americans, relying on the principles articulated in Norris v. Alabama to demonstrate a pattern of discrimination.

• Example 3: Flawed Jury Pool Creation

  Consider a city where jury pools are drawn exclusively from voter registration lists. Historically, a specific low-income neighborhood, predominantly inhabited by a particular minority group, has faced significant barriers to voter registration due to language access issues, lack of transportation to registration sites, or targeted misinformation campaigns. As a result, very few individuals from this neighborhood are ever registered to vote, and consequently, almost none are ever called for jury service. A defendant from this community, facing trial, could argue that this method of jury selection, while seemingly neutral, effectively creates a "systematic and arbitrary exclusion" of their demographic group from jury service, a situation that Norris v. Alabama sought to prevent.