Edmonson v. Leesville Concrete Company
| Edmonson v. Leesville Concrete Company | |
|---|---|
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| Argued January 15, 1991 Decided June 3, 1991 |
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| Full case name | Edmonson v. Leesville Concrete Company |
| Citations | 500 U.S. 614 (more) |
| Holding | |
| Race-based use of peremptory challenges during jury selection in a civil trial between private litigants violates due process. | |
| Court membership | |
| Case opinions | |
| Majority | Kennedy, joined by White, Marshall, Blackmun, Stevens, Souter |
| Dissent | O'Connor, joined by Rehnquist, Scalia |
| Dissent | Scalia |
| Laws applied | |
| U.S. Const. amend. V | |
Edmonson v. Leesville Concrete Company, 500 U.S. 614 (1991), was a United States Supreme Court case which held that peremptory challenges may not be used to exclude jurors on the basis of race in civil trials. Edmonson extended the court's similar decision in Batson v. Kentucky (1986), a criminal case. The Court applied the equal protection component of the Due Process Clause of the Fifth Amendment, as determined in Bolling v. Sharpe (1954), in finding that such race-based challenges violated the Constitution.
A black construction worker, Thaddeus Donald Edmonson, was injured during work on federal property. He sued Leesville Concrete Company for negligence leading to his injuries. During jury selection, Leesville used two of their three peremptory challenges on black jurors, leaving a panel of twelve with one African-American. Edmonson, citing Batson, requested that the trial court require Leesville give a race-neutral reason for the peremptory challenges to black jurors, but the court refused. The jury found that Leesville was responsible for 20% of Edmonson's injury and awarded him $18,000. The United States Court of Appeals for the Fifth Circuit reversed the decision, holding that parties become state actors during jury selection, and so Batson requires race-neutral selection in civil cases. When the Fifth Circuit reheard the case en banc, they affirmed the original District Court decision. Recognizing a circuit split, the Supreme Court granted certiorari.
Justice Anthony Kennedy wrote the opinion for the majority. Justice Kennedy began with a long line of cases where the court held that racial discrimination was impermissible in jury selection before a criminal trial. He then pointed out that although the Court had never indicated such discrimination was permitted in a civil trial, either, it also holds that federal law restrains the actions of government, not private actors. To decide whether to apply federal law, Justice Kennedy applied a two-part test from Lugar v. Edmondson Oil Co 457 U.S. 922 (1982). The first part of the test is whether the constitutional deprivation, in this case the right to a fair and impartial jury, resulted from a right rooted in state authority. Kennedy found, almost summarily, that peremptory challenges' intimate role in shaping a jury meant the case met the first part of the test. The second part of the test is whether the private party, Leesville and its counsel, was acting as a "state actor".
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