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Keywords

precedentappealtrialmotiondiscriminationlife imprisonment
appealtrialmotiondiscriminationgrand jurypetit jurylife imprisonment

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Hernandez v. State of Tex., 347 U.S. 475, 74 S.Ct. 667, 98 L.Ed. 866

Facts

Pete Hernandez was indicted for the murder of Joe Espinosa in Jackson County, Texas, and subsequently convicted and sentenced to life imprisonment. Prior to the trial, Hernandez filed motions to quash the indictment and jury panel, claiming that persons of Mexican descent were systematically excluded from jury service despite being qualified. The trial court denied these motions, leading to an appeal after the Texas Court of Criminal Appeals affirmed the trial court's decision.

The petitioner, Pete Hernandez, was indicted for the murder of one Joe Espinosa by a grand jury in Jackson County, Texas. He was convicted and sentenced to life imprisonment. The Texas Court of Criminal Appeals affirmed the judgment of the trial court. Prior to the trial, the petitioner, by his counsel, offered timely motions to quash the indictment and the jury panel. He alleged that persons of Mexican descent were systematically excluded from service as jury commissioners, grand jurors, and petit jurors, although there were such persons fully qualified to serve residing in Jackson County.

Issue

Did the systematic exclusion of persons of Mexican descent from jury service in Jackson County violate the Equal Protection Clause of the Fourteenth Amendment?

Did the systematic exclusion of persons of Mexican descent from jury service in Jackson County violate the Equal Protection Clause of the Fourteenth Amendment?

Rule

The exclusion of a class of persons from jury service based on ancestry or national origin constitutes discrimination prohibited by the Fourteenth Amendment, which guarantees equal protection of the laws.

The exclusion of otherwise eligible persons from jury service solely because of their ancestry or national origin is discrimination prohibited by the Fourteenth Amendment.

Analysis

The Supreme Court analyzed the evidence presented, which demonstrated that persons of Mexican descent were a distinct class in the community and had been systematically excluded from jury service. The Court applied the precedent set in Norris v. Alabama, which established that proof of a substantial population segment being qualified yet excluded from jury service constitutes prima facie evidence of discrimination. The Court found that the State's general assertions of non-discrimination were insufficient to counter the strong evidence of exclusion.

The petitioner established that 14% of the population of Jackson County were persons with Mexican or Latin American surnames, and that 11% of the males over 21 bore such names. The State of Texas stipulated that ‘for the last twenty-five years there is no record of any person with a Mexican or Latin American name having served on a jury commission, grand jury or petit jury in Jackson County.'

Conclusion

The Supreme Court reversed the judgment of conviction, holding that Hernandez was denied his constitutional right to a jury from which members of his class were not systematically excluded.

The judgment of conviction must be reversed.

Who won?

Pete Hernandez prevailed in the case because the Supreme Court found that the systematic exclusion of persons of Mexican descent from jury service violated the Equal Protection Clause.

The petitioner prevailed because the Court found that the systematic exclusion of persons of Mexican descent from jury service violated the Equal Protection Clause.

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