Patterson v. Alabama
| Patterson v. Alabama | |
|---|---|
 | |
| Argued February 15, 18, 1935 Decided April 1, 1935 | |
| Full case name | Patterson v. Alabama |
| Citations | 294 U.S. 600 (more) 294 U.S. 600 (1935) |
| Holding | |
| An African-American defendant is denied due process rights if the jury pool excludes African Americans. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Hughes |
| Reynolds took no part in the consideration or decision of the case. | |
| Laws applied | |
| 14th amendment, 1st amendment | |
Patterson v. Alabama, 294 U.S. 600 (1935), was a United States Supreme Court case which held that an African-American defendant is denied due process rights if the jury pool excludes African-Americans.
Background
This case was the second landmark decision arising out of the Scottsboro Boys trials (the first was the 1932 case, Powell v. Alabama). Haywood Patterson, along with several other African-American defendants, were tried for raping two white women in 1931 in Scottsboro, Alabama. The trials were rushed, there was virtually no legal counsel, and no African-Americans were permitted in the jury. All defendants, including Patterson, were convicted. The Communist Party of the United States assisted the defendants and appealed to the Supreme Court, which overturned the convictions in 1932 (in the Powell v. Alabama decision) due to lack of legal counsel.
A second set of trials was then held in Decatur, Alabama. In spite of lack of evidence, the jury convicted Patterson to death in the electric chair. Judge James Edwin Horton overturned the verdict, and a third trial was held in 1933. The third trial also resulted in a death penalty verdict. No African Americans were present in any of the juries, nor were any ever considered for jury duty in Alabama. This decision was appealed to the Supreme Court, on the basis that the absence of African Americans from the jury pool denied the defendants due process.
The Supreme Court agreed, and the convictions were overturned.
In 1936, the defendants were tried, some for the fourth time, again for rape. In this trial, the verdicts were again guilty, but sentences were long prison terms, rather than the death penalty.
Norris v. Alabama
The Supreme Court simultaneously decided a nearly identical case in Norris v. Alabama, 294 U.S. 587 (1935), involving Clarence Norris, another Scottsboro Boy defendant. In the Norris decision, the court held that "exclusion of all negroes from a grand jury by which a negro is indicted, or from the petit jury by which he is tried for the offense, resulting from systematic and arbitrary exclusion of negroes from the jury lists solely because of their race or color, is a denial of the equal protection of the laws guaranteed to him by the Fourteenth Amendment."
The Norris decision and Patterson cases were argued and decided concurrently.
Notes and references
- Patterson, Haywood; Conrad, Earl (1950). Scottsboro boy. Doubleday. ISBN 978-1-59740-102-9.
External links
- Text of Patterson v. Alabama - 294 U.S. 600 (1935) is available from: Justia
- Norris v. Alabama - 294 U.S. 587 (1935)