Edmonson v. Leesville Concrete Company
Edmonson v. Leesville Concrete Company is a significant Supreme Court case from 1991 that addresses the issue of racial discrimination in jury selection, specifically in civil cases. The case arose when Thaddeus Edmonson, an African American construction worker, sued his employer after sustaining injuries in a workplace accident. During jury selection, the company’s lawyers used peremptory challenges to dismiss two black jurors, prompting Edmonson to challenge these dismissals based on the precedent established in Batson v. Kentucky, which prohibited racial discrimination in criminal jury selection. The core question was whether this principle applied in civil cases as well.
Ultimately, the Supreme Court ruled in a 6-3 decision that racially motivated jury challenges are unconstitutional in civil proceedings, reinforcing the idea that such discriminatory practices constitute "state action" and must align with constitutional mandates against racial discrimination. The dissenting opinion argued that the Equal Protection Clause only pertains to government actions, not to the actions of private litigants. This case has broader implications for civil rights and the integrity of the judicial process, emphasizing the importance of diversity and fairness in jury composition.
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Edmonson v. Leesville Concrete Company
Thaddeus Edmonson, an African American construction worker, sued his employer, the Leesville Concrete Company, in 1988, claiming compensation for injuries suffered in a workplace accident. Edmonson invoked his right to a trial by jury. During the pretrial examination of potential jurors, the company’s lawyers used their peremptory challenges to excuse two of the three black members of the panel. Edmonson asked the district court to require the company to provide a race-neutral explanation of the dismissals of the black panelists. Under Batson v. Kentucky (1986), racial motivation for juror challenges was held unconstitutional in criminal cases. In Batson, the U.S. Supreme Court had reasoned that the use of race as a criterion in jury challenges by the prosecution violates the equal protection clause of the U.S. Constitution. Edmonson’s case presented the issue of whether such dismissals are improper in civil cases. The trial court denied Edmonson’s request and, after conflicting decisions in the court of appeals, he appealed to the Supreme Court.
In 1991 Justice Anthony Kennedy wrote for the Court in a 6–3 decision holding that racially based juror challenges are unconstitutional even in civil cases. Because the juror challenges use the power of the government to select jury members, the discrimination becomes “state action” even though invoked by a private litigant. All state action must be consistent with constitutional rules forbidding racial discrimination.
Justice Sandra Day O’Connor dissented, arguing that only governmental discrimination is forbidden by the equal protection clause and that the act of Leesville Concrete’s counsel was not state action.
Bibliography
Carbone, Christina S., and Victoria C. Plaut. “Diversity and the Civil Jury.” William & Mary Law Rev. 55.3 (2014): 837–884. Academic Search Complete. Web. 21 Apr. 2015.
Graham, Charlotte A. “Edmonson’s Historic Court Case Featured.” Laurel Leader-Call (MS) 22 June 2009: State and regional. NewsBank. Web. 21 Apr. 2015.
Josephs, M. L. “14th Amendment - Peremptory Challenges and the Equal-Protection Clause - Edmonson v. Leesville Concrete Co, 111 S Ct 2077 (1991).” Jour. of Criminal Law & Criminology 82.4 (n.d.): 1000–1028. Social Sciences Citation Index. Web. 21 Apr. 2015.
Krezminski, Allan D. “Peremptory Challenges after Edmonson v. Leesville Concrete.” Wisconsin Lawyer 1992: 18. Print.
Tomkovicz, James J. “Twenty-Five Years Of Batson: An Introduction To Equal Protection Regulation Of Peremptory Jury Challenges.” Iowa Law Review 97.5 (2012): 1393–1423. Academic Search Complete. Web. 21 Apr. 2015.