Castaneda v. Partida
430 U.S. 482 (1977)
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Rule of Law:
A defendant can establish a prima facie case of purposeful discrimination in grand jury selection under the Equal Protection Clause by showing a significant statistical disparity between the percentage of their identifiable group in the total population and the percentage summoned for grand jury service over a significant period. The burden then shifts to the State to rebut this presumption of discrimination, which cannot be overcome simply by asserting that members of the defendant's group form a "governing majority" in the community.
Facts:
- Rodrigo Partida, a Mexican-American, was indicted for burglary in Hidalgo County, Texas.
- According to the 1970 census, Hidalgo County's population was 79.1% Mexican-American.
- A review of the county's grand jury records over an 11-year period (1962-1972) showed that, on average, only 39% of persons summoned to serve as grand jurors were Mexican-American.
- Texas used a subjective "key man" system for grand jury selection, where court-appointed jury commissioners selected prospective jurors from the community.
- Three of the five jury commissioners who selected the grand jury list for Partida's case were Mexican-American.
- Many other elected officials in Hidalgo County, including the state judge who appointed the jury commissioners, were also Mexican-American.
Procedural Posture:
- Rodrigo Partida was convicted of burglary in a Texas state district court.
- Partida's motion for a new trial, alleging discrimination in grand jury selection, was denied by the state district court.
- Partida appealed to the Texas Court of Criminal Appeals, which affirmed the conviction, holding he failed to make a prima facie case of discrimination.
- Partida filed a petition for a writ of habeas corpus in the U.S. District Court for the Southern District of Texas.
- The U.S. District Court found Partida made a 'bare prima facie case' but concluded it was rebutted by the 'governing majority' theory, and dismissed the petition.
- Partida, as appellant, appealed to the U.S. Court of Appeals for the Fifth Circuit, which reversed, finding the state (appellee) had failed to rebut the prima facie case.
- The Sheriff of Hidalgo County, Castaneda, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does evidence that an identifiable group constitutes a 'governing majority' in a county, by itself, rebut a defendant's prima facie showing of purposeful discrimination in the grand jury selection process established through significant statistical underrepresentation?
Opinions:
Majority - Mr. Justice Blackmun
No. Evidence that an identifiable group is a 'governing majority' does not, by itself, rebut a prima facie case of purposeful discrimination in grand jury selection. A defendant establishes a prima facie case by showing that their group is a recognizable class that has been substantially underrepresented over time due to a selection procedure susceptible to abuse. Here, Partida established a prima facie case with statistics showing a 40% disparity between the Mexican-American population (79.1%) and those summoned for grand jury service (39%) over 11 years, combined with Texas's subjective 'key man' selection system. The burden then shifted to the State to provide a neutral explanation. The State failed to meet this burden, offering no testimony from the jury commissioners to explain the disparity. The 'governing majority' theory is an inadequate rebuttal because it would be unwise to presume as a matter of law that members of a particular group will not discriminate against others of their own group.
Concurring - Mr. Justice Marshall
No. The statistical evidence and the discretionary selection system clearly established a prima facie case of discrimination, and the state offered no explanation. The dissent's reliance on the 'governing majority' theory is based on flawed assumptions about human nature. Social science research indicates that members of minority groups who achieve success sometimes adopt the majority's negative attitudes toward their own group to disassociate themselves. The Court should not rely on broad stereotypes about group behavior; the only reliable method to determine the commissioners' actions is for the State to produce testimony about the selection process, which it failed to do.
Dissenting - Mr. Chief Justice Burger
Yes. Partida failed to establish a prima facie case of discrimination in the first place. The statistics used were based on gross population figures rather than the 'eligible' population, which should account for legal qualifications like citizenship and literacy. Common sense suggests that after accounting for these factors, the statistical disparity would be greatly reduced or eliminated. Furthermore, focusing on 11-year-old data is misleading when recent grand jury lists, including the one in Partida's case, showed substantial representation of Mexican-Americans (around 50%).
Dissenting - Mr. Justice Powell
Yes. While a statistical disparity existed, it must be considered in light of other evidence of intent, as required by the Equal Protection Clause. The unique circumstances of this case—where Mexican-Americans held political control, the presiding judge was Mexican-American, and a majority of the jury commissioners were Mexican-American—render an inference of purposeful discrimination against Mexican-Americans improbable. It is more likely that the statistical disparity stemmed from neutral causes. The District Court's finding that no intentional discrimination occurred was not clearly erroneous and should have been respected, as it is illogical to conclude that a controlling majority group is systematically discriminating against itself.
Dissenting - Mr. Justice Stewart
Yes. The findings of fact made by the District Court in this case were not 'clearly erroneous.' Based on those findings, which concluded there was no constitutional violation, the judgment of the Court of Appeals should be reversed. I am in substantial agreement with the dissents of The Chief Justice and Mr. Justice Powell.
Analysis:
This decision solidified the 'rule of exclusion' method for establishing a prima facie case of jury discrimination using statistical disparities under the Equal Protection Clause. It clarified that a significant statistical disparity, coupled with a subjective selection system, shifts the burden of proof to the state. Critically, the Court rejected the novel 'governing majority' theory as a legally sufficient rebuttal, establishing that the state cannot rely on demographic assumptions about the selectors but must produce actual evidence of its non-discriminatory selection process. This prevents courts from creating a legal presumption that members of a group will not discriminate against their own kind.
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