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Hernandez v. Texas

Supreme Court of United States
347 U.S. 475 (1954)
ELI5:

Rule of Law:

The Fourteenth Amendment's Equal Protection Clause prohibits the systematic exclusion from jury service of any distinct class of persons based on ancestry or national origin, extending its protection beyond the two-class theory of discrimination based solely on race or color.


Facts:

  • Pete Hernandez, a person of Mexican descent, was charged with murder in Jackson County, Texas.
  • Approximately 14% of the population of Jackson County consisted of persons with Mexican or Latin-American surnames.
  • Evidence showed that persons of Mexican descent were treated as a distinct class within the community.
  • Children of Mexican descent were historically required to attend a segregated school for the first four grades.
  • A local restaurant prominently displayed a sign reading 'No Mexicans Served.'
  • The county courthouse maintained two men's toilets: one unmarked, and another marked 'Colored Men' and 'Hombres Aqui' ('Men Here').
  • Despite their substantial population and eligibility, no person with a Mexican or Latin American surname had served on a jury commission, grand jury, or petit jury in Jackson County for the preceding 25 years.

Procedural Posture:

  • Pete Hernandez was indicted for murder by a grand jury in a Texas state trial court in Jackson County.
  • Prior to trial, Hernandez's counsel filed motions to quash the indictment and the jury panel, alleging systematic exclusion of persons of Mexican descent from jury service.
  • The trial court conducted a hearing and denied the motions.
  • Following a trial, Hernandez was convicted and sentenced to life imprisonment.
  • Hernandez appealed to the Texas Court of Criminal Appeals, the state's highest criminal court, arguing the trial court erred in denying his motions.
  • The Texas Court of Criminal Appeals affirmed the trial court's judgment.
  • The U.S. Supreme Court granted Hernandez's petition for a writ of certiorari to review the decision.

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Issue:

Does the systematic exclusion of persons of Mexican descent from service as jury commissioners, grand jurors, and petit jurors in a county where they constitute a substantial and distinct class violate the Equal Protection Clause of the Fourteenth Amendment?


Opinions:

Majority - Mr. Chief Justice Warren

Yes, the systematic exclusion of otherwise eligible persons from jury service solely because of their ancestry or national origin violates the Equal Protection Clause of the Fourteenth Amendment. The Court rejected the State of Texas's argument that the Fourteenth Amendment contemplates only two classes—white and Negro. The protection of the amendment extends to any group that can be shown to be a distinct class singled out for different treatment by the community. Hernandez successfully demonstrated that persons of Mexican descent constituted such a class in Jackson County through evidence of segregation in schools, public accommodations, and even courthouse facilities. Having established a distinct class, Hernandez met his burden of proving discrimination by showing that this class, which formed 14% of the population, had been completely excluded from jury service for 25 years. This long-continued absence established a prima facie case of systematic exclusion, which the State's general assertions of non-discrimination from jury commissioners were insufficient to rebut.



Analysis:

This landmark decision was the first to explicitly extend the protections of the Fourteenth Amendment to Mexican Americans, establishing them as a protected class against discrimination. By rejecting the 'two-class theory' of race, the Court broadened the scope of the Equal Protection Clause to cover any distinct ethnic or national origin group subject to community prejudice. This ruling created a vital precedent for other minority groups to challenge discriminatory jury selection practices and other forms of state-sanctioned discrimination. It affirmed that equal protection is not a static concept but one that evolves to protect any group that becomes a target of community prejudice.

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