Patterson v. Alabama

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Patterson v. Alabama
L. Ed. 1082
Case history
PriorPatterson v. State, 229 Ala. 270, 156 So. 567 (1934); cert. granted, 293 U.S. 554 (1935).
Holding
An African-American defendant is denied due process rights if the jury pool excludes African Americans.
Court membership
Chief Justice
Charles E. Hughes
Associate Justices
Case opinion
MajorityHughes, joined by Van Devanter, Brandeis, Sutherland, Butler, Stone, Roberts, Cardozo
McReynolds took no part in the consideration or decision of the case.
Laws applied
amends. I, XIV

Patterson v. Alabama, 294 U.S. 600 (1935), was a

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

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 sentenced 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 included 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.

Notes and references

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External links