Ristaino v. Ross
424 U.S. 589, 47 L. Ed. 2d 258, 1976 U.S. LEXIS 28 (1976)
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Rule of Law:
The Due Process Clause of the Fourteenth Amendment does not create a per se constitutional rule requiring a trial judge to question prospective jurors specifically about racial prejudice in every case involving an interracial crime. Such an inquiry is only constitutionally required when special circumstances indicate a significant likelihood that racial prejudice might infect the trial.
Facts:
- James Ross, Jr., a Black man, and two other Black men were charged with violent crimes.
- The alleged crimes included armed robbery, assault and battery by means of a dangerous weapon, and assault and battery with intent to murder.
- The victim of the alleged crimes was a white man.
- The victim was employed by Boston University as a uniformed security guard.
Procedural Posture:
- James Ross, Jr. was convicted of violent crimes in a Massachusetts state trial court.
- On direct appeal, the Supreme Judicial Court of Massachusetts affirmed the conviction.
- The U.S. Supreme Court granted certiorari, vacated the state court's judgment, and remanded for reconsideration in light of its decision in Ham v. South Carolina.
- On remand, the Supreme Judicial Court of Massachusetts again affirmed the conviction.
- Ross filed a petition for a writ of habeas corpus in the U.S. District Court, which granted the writ.
- The government appealed to the U.S. Court of Appeals for the First Circuit, which affirmed the District Court's decision.
- The U.S. Supreme Court granted certiorari to review the decision of the Court of Appeals.
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Issue:
Does the Due Process Clause of the Fourteenth Amendment require a trial judge, upon a defendant's request, to question prospective jurors specifically about racial prejudice when the case involves a Black defendant accused of violent crimes against a white victim?
Opinions:
Majority - Mr. Justice Powell
No, the Due Process Clause does not automatically require a trial judge to question prospective jurors about racial prejudice in every interracial crime case. The court distinguished this case from Ham v. South Carolina, where racial issues were 'inextricably bound up with the conduct of the trial' because the defendant was a well-known civil rights activist who claimed he was framed. Here, the only racial component was that the defendant was Black and the victim was white, which does not by itself constitute a 'special circumstance' creating a constitutionally significant likelihood of prejudice. The trial court has broad discretion in conducting voir dire, and its generalized inquiry into bias, combined with specific questions about the victim's status as a security guard, was sufficient to satisfy the constitutional requirement of an impartial jury.
Concurring - Mr. Justice White
No, the conviction should not be overturned. The ruling in Ham v. South Carolina announced a new constitutional rule that should not be applied retroactively to trials, like this one, that occurred before the Ham decision was issued.
Dissenting - Mr. Justice Marshall
Yes, the Due Process Clause should require such questioning in these circumstances. The majority's refusal to apply the principles of Ham and Aldridge v. United States in this case effectively renders those precedents meaningless. Failing to require questions about racial bias in a case involving a violent interracial crime ignores the 'essential demands of fairness' necessary for a truly impartial jury.
Analysis:
This decision significantly narrows the scope of the Court's prior holding in Ham v. South Carolina. It establishes that the mere fact of an interracial crime is not, by itself, a 'special circumstance' that constitutionally compels a judge to conduct a specific inquiry into racial bias during voir dire. The ruling reinforces the trial judge's broad discretion in managing jury selection and places a higher burden on defendants to demonstrate that racial issues are 'inextricably bound up with the conduct of the trial' before such specific questioning is constitutionally mandated. This creates a distinction between cases where race is merely a demographic fact and those where it is a central element of the defense or evidence.
