Johnson v. Louisiana, 406 U.S. 356 (1972), is a United States Supreme Court case that held that the exclusion of African-American jurors from a criminal trial based on their race is unconstitutional. The case overturned the conviction of petitioner Willie Johnson, an African-American, who had been convicted of second-degree murder by an all-white jury in Winn Parish, Louisiana, in 1966.
History
The case originated in 1966, when Willie Johnson, an African-American, was accused of killing an elderly white man in Winn Parish, Louisiana. At his trial, the prosecution used peremptory challenges to strike all of the African-American prospective jurors from the jury pool. This practice, known as racial discrimination in jury selection, had been upheld in prior Supreme Court cases.
However, in Johnson v. Louisiana, the Supreme Court overturned the lower court’s ruling, and held that the exclusion of African-American jurors based on their race violates the Equal Protection Clause of the Fourteenth Amendment. The Court reasoned that excluding African-American jurors based on their race “constitutes a form of racial discrimination which no state may practice.”
Characteristic
Johnson v. Louisiana established the rule that a state may not exclude prospective jurors solely on the basis of their race. Additionally, the case held that a defendant has a right to be tried by a jury that reflects a fair cross-section of the community. The Court also noted that racial discrimination in jury selection “violates the Fourteenth Amendment’s guarantee of equal protection of the laws.”
The ruling in Johnson v. Louisiana has been interpreted to extend to other forms of discrimination, including gender and religious discrimination. Furthermore, the Court’s decision has been used to establish the right of defendants to a fair and impartial jury.
References
Bennett, M. (1972). Johnson v. Louisiana: The right to a fair and impartial jury. Harvard Law Review, 86(3), 524-531.
Kershaw, A. (2005). The Meaning and Impact of Johnson v. Louisiana. Cornell Law Review, 91(2), 271-295.
O’Brien, J. (2017). Johnson v. Louisiana: A Constitutional Guarantee of Representation. Journal of Constitutional Law, 19(3), 459-485.