Campbell v. Louisiana
1998 U.S. LEXIS 2787, 523 U.S. 392, 140 L. Ed. 2d 551 (1998)
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Rule of Law:
A white criminal defendant has standing to object to racial discrimination against black persons in the selection of grand jurors, asserting both the equal protection rights of the excluded jurors and his own due process rights, particularly when the selection process affects the grand jury's composition.
Facts:
- Terry Campbell, who is white, was indicted on one count of second-degree murder in Evangeline Parish, Louisiana.
- Between January 1976 and August 1993, no black person served as a grand jury foreperson in Evangeline Parish.
- During that same period, more than 20% of the registered voters in Evangeline Parish were black persons.
- In Louisiana, the judge selects the grand jury foreperson from the grand jury venire before the remaining grand jury members are chosen by lot.
- The Louisiana grand jury foreperson possesses the same full voting powers as other grand jury members.
Procedural Posture:
- Terry Campbell filed a timely pretrial motion in the trial court to quash the indictment, alleging racial discrimination in the selection of grand jury forepersons, but the trial judge denied the motion, ruling Campbell lacked standing.
- After his first trial resulted in a mistrial, Campbell was retried, convicted of second-degree murder, and sentenced to life in prison.
- Campbell renewed his challenge to the grand jury foreperson selection procedures in a motion for a new trial, which was denied by the trial court.
- The Louisiana Court of Appeal reversed the trial court's decision, holding that Campbell (as appellant) had standing under Powers v. Ohio, and remanded the case for an evidentiary hearing.
- The Louisiana Supreme Court reversed the Court of Appeal's ruling, distinguishing Powers and finding Hobby v. United States did not afford Campbell standing to raise a due process objection, believing the Louisiana grand jury foreperson's duties were ministerial. It remanded the case for the Court of Appeal to address Campbell's other asserted points of error.
- After the Louisiana Court of Appeal rejected Campbell's remaining claims, the Louisiana Supreme Court refused to reconsider its ruling on the grand jury issue.
- The U.S. Supreme Court granted certiorari.
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Issue:
Does a white criminal defendant have standing to challenge alleged racial discrimination against black persons in the selection of a grand jury foreperson when that selection process also determines one member of the grand jury itself?
Opinions:
Majority - Justice Kennedy
Yes, a white criminal defendant has standing to challenge alleged racial discrimination against black persons in the selection of a grand jury foreperson when that selection process also determines one member of the grand jury itself. The Court found that Campbell satisfied the three preconditions for third-party standing established in Powers v. Ohio. First, Campbell suffered an "injury in fact" because discrimination in the grand jury selection process "strikes at the fundamental values of our judicial system" and "casts doubt on the integrity of the judicial process," thereby depriving him of the certainty of a fair verdict. This is especially true in Louisiana, where the foreperson is selected from the venire before other jurors and serves as a voting member, thus affecting the composition of the grand jury itself, unlike the federal system discussed in Hobby v. United States. Second, Campbell had a "close relationship" to the excluded black jurors, sharing a common interest in eliminating discrimination, and having a strong incentive to advocate effectively as a victory could overturn his conviction. Third, there was a "hindrance" to the excluded jurors asserting their own rights due to economic burdens and small financial rewards for litigation. The Court also held that Campbell had standing to raise his own due process rights, noting that Hobby had implicitly assumed such standing and that Louisiana's system, where the foreperson is a grand juror selected outside the random draw, is distinct from the ministerial role described in Hobby. The Court declined to address Campbell's fair-cross-section claim because it was not properly presented to the state appellate courts.
Concurring-in-part-and-dissenting-in-part - Justice Thomas
No, a white criminal defendant should not have standing to challenge alleged racial discrimination against black persons in the selection of grand jurors. Justice Thomas argues that Powers v. Ohio was wrongly decided and should be overruled, contending that it distorted standing principles and equal protection law. He asserts that the defendant in Powers did not suffer an "injury in fact" and that the "injury in perception" the Court found is not a true injury. He also disputes the "close relationship" between defendants and excluded jurors and the claim of substantial obstacles for jurors to assert their own rights. Even if Powers were correctly decided, its rationales are inapplicable here. There is no "overt wrong" or public humiliation in a judge's selection of a single grand jury member, as there is in peremptory strikes. Furthermore, the petitioner's own use of peremptory strikes to eliminate black persons from his petit jury venire belies his claim of injury. The grand jury's composition did not affect the trial jury's verdict, and systematic discrimination in foreperson selection provides ample opportunity for affected individuals to seek relief themselves. Justice Thomas concurs with the majority on the due process standing argument (Part IV) because it pertains to the defendant's own rights, and on the fair-cross-section issue (Part V), as well as the factual background (Parts I and II).
Analysis:
This case significantly broadens the application of third-party standing in racial discrimination claims within the criminal justice system, extending the Powers v. Ohio rationale from petit jury selection to grand jury composition challenges. By distinguishing Louisiana's grand jury foreperson selection process, where the foreperson is a voting grand juror chosen non-randomly, from the federal system in Hobby v. United States, the Court emphasizes that discrimination affecting the grand jury's very makeup constitutes a direct injury to the integrity of the judicial process. This decision reinforces the principle that systemic discrimination, even when not directly targeting the defendant's race, undermines fundamental fairness and can be challenged by a defendant whose conviction stems from that tainted process, offering a potent tool against discriminatory practices in grand jury selection nationwide, particularly in states with similar foreperson selection methods.
