Petitioner
Haywood Patterson
Respondent
State of Alabama
Petitioner's Claim
That the exclusion of blacks from a jury list should invalidate the conviction of a black defendant.
Chief Lawyer for Petitioner
Walter H. Pollak
Chief Lawyer for Respondent
Thomas E. Knight, Jr.
Justices for the Court
Louis D. Brandeis, Pierce Butler, Benjamin N. Cardozo, Charles Evans Hughes (writing for the Court), Owen Josephus Roberts, Harlan Fiske Stone, George Sutherland, Willis Van Devanter
Justices Dissenting
None (James Clark McReynolds did not participate)
Place
Washington, D.C.
Date of Decision
1 April 1935
Decision
Hayward Patterson's conviction was overturned based on evidence of the systematic exclusion of blacks from jury duty.
Significance
The Supreme Court's decision in Patterson v. Alabama was the second oftwo important rulings it would issue in the Scottsboro rape case. The controversial trials galvanized the country and highlighted the problem of racial justice in the American South. The Scottsboro trials became emblematic of judicial miscarriage and a rallying cry for civil rights leaders for years to come.
The Scottsboro Case
The Scottsboro case, one of the most racially charged criminal trials in American history, began in March of 1931, when nine black youths ranging in age from 13 to 21 were arrested and charged with raping two white girls, Ruby Bates and Victoria Price, near Scottsboro, Alabama. The "Scottsboro boys" pleadednot guilty to the 20 indictments brought against them. Despite a spirited defense led by a coalition of Communists and civil rights leaders, an all-whitejury rejected their pleas. Eight of the boys were found guilty, while a mistrial was declared in the case 13-year-old Roy Wright. The eight convicted defendants were sentenced to death on 9 April 1931.
Given a racial climate overwhelmingly hostile to blacks, the verdicts came aslittle surprise. The jury ignored a great deal of evidence that tended to exonerate the defendants. Further complicating the defense was the appointmentby the court of Milo Moody, an inexperienced lawyer, as defense attorney in the case. A crowd of some 10,000 whites gathered outside the courthouse duringthe critical days of the trial, demonstrating and calling for vigilante justice.
The convictions likewise generated a passionate reaction worldwide. Labor leaders and radical organizations held rallies to protest the jury's verdict. Demonstrations were held as far away as Germany. Many of the leading intellectuals of the day, including Albert Einstein, signed a petition calling for therelease of the defendants. Eventually, these supporters were joined by one ofthe alleged victims, Ruby Bates, who recanted her testimony that she had been raped by the defendants. In November of 1932, the U.S. Supreme Court, in the case of Powell v. Alabama, overturned the convictions. The Court ruled that the Scottsboro boys had been denied due process of the law because the judge had been unacceptably casual in appointing their defense lawyer. Newtrials were set for all nine defendants.
Patterson's Case
Haywood Patterson was tried first. His defense attorneys asked that the casebe thrown out on the grounds that no blacks had been on the first jury. The judge dismissed this objection, and an all-white jury was chosen a second time. Again, despite substantial evidence that suggested otherwise, Patterson wasfound guilty. Dismayed by this seemingly willful disregard for the evidence,the judge set aside the jury's verdict and ordered a new trial. For a thirdtime, and again with a jury picked from a list that did not include blacks, Patterson was found guilty as charged. On 6 December 1933, Haywood Patterson was once again sentenced to death. He appealed the verdict to the Supreme Court of Alabama, which affirmed. Patterson then took his case before the U.S. Supreme Court.
In presenting his case, Patterson contended that there was a long-standing, systematic, and arbitrary exclusion of qualified blacks from jury service, based solely on their race, in violation of the Fourteenth Amendment of the U.S.Constitution. The state of Alabama argued on technical legal grounds that the Supreme Court had no jurisdiction over the case. Complicating matters further was the disposition of a second Scottsboro case, Norris v. Alabama(1935), argued purely on the merits and without the technical controversies.
Norris Case Decided
The case of Clarence Norris was decided first. On 1 April, Chief Justice Hughes delivered the opinion of the High Court, which held that the exclusion ofblacks from jury service was pervasive and deliberate. In rendering its decision, the Court relied on overwhelming evidence of tampering with jury rolls to indicate that blacks had been considered for jury service--when in fact they had not been. Hughes rejected the state of Alabama's contention that many blacks simply were not qualified for jury service. He wrote:
The decision in Norris v. Alabama was to prove pivotal for Haywood Patterson's case as well. While the Supreme Court agreed with the state of Alabama that Patterson's case should have been thrown out for technical legal violations, it was reluctant to send a man to death on the same evidence that hadbeen relied upon to grant Norris a new trial. "We cannot ignore the exceptional features of this case," Chief Justice Hughes wrote in his majority opinion. He concluded that the Alabama State Supreme Court should be given anotherchance to rule on the matter in light of the new evidence. Hughes also strongly hinted that the U.S. Supreme Court would take another look at the case ifPatterson's conviction were not overturned and a new trial granted.
In the end, Haywood Patterson was granted a new trial. But the result was thesame. In 1936, a jury composed of 13 whites and one black found him guilty.He was sentenced to 75 years in prison. He pursued another appeal, but this time the Supreme Court refused to hear his case. Patterson died in prison in 1952.
Impact
In the case of Patterson v. Alabama the Supreme Court attempted to correct what it perceived to be a gross injustice. In overlooking the technicaldefects of Patterson's case, the Court signaled that it would not let fidelity to arcane legal protocols prevent it from exonerating an individual from execution.
Related Cases
Jury Nullification
Jury nullification takes place when a jury acquits a defendant even though the prosecution has proven the defendant's guilt beyond all reasonable doubt. The jury acquits the defendant because they disagree with the law whereby he or she is charged, and their acquittal serves as a form of protest.
The idea of jury nullification originated in England and gained popularity among rebellious American colonists, who used it as a means of registering their dissatisfaction with British rule. In the years leading up to the Civil War, jury nullification became popular with Abolitionists, who likewise used itto protest what they saw as an unjust system: the Fugitive Slave Law, which required the return of runaway slaves. During the late 1800s and early 1900s,white Southern juries, by refusing to convict white men guilty of killing blacks, used jury nullification for less idealistic purposes.
Despite its long and varied past, jury nullification did not gain popular attention until 3 October 1995, when a mostly African American jury in the O. J.Simpson murder case issued a "not guilty" verdict, an act which many saw asan attempt to address past racial injustices.
Sources
Fully Informed Jury Association (FIJA). http://www.primenet.com/~slack.
Haywood Patterson
Respondent
State of Alabama
Petitioner's Claim
That the exclusion of blacks from a jury list should invalidate the conviction of a black defendant.
Chief Lawyer for Petitioner
Walter H. Pollak
Chief Lawyer for Respondent
Thomas E. Knight, Jr.
Justices for the Court
Louis D. Brandeis, Pierce Butler, Benjamin N. Cardozo, Charles Evans Hughes (writing for the Court), Owen Josephus Roberts, Harlan Fiske Stone, George Sutherland, Willis Van Devanter
Justices Dissenting
None (James Clark McReynolds did not participate)
Place
Washington, D.C.
Date of Decision
1 April 1935
Decision
Hayward Patterson's conviction was overturned based on evidence of the systematic exclusion of blacks from jury duty.
Significance
The Supreme Court's decision in Patterson v. Alabama was the second oftwo important rulings it would issue in the Scottsboro rape case. The controversial trials galvanized the country and highlighted the problem of racial justice in the American South. The Scottsboro trials became emblematic of judicial miscarriage and a rallying cry for civil rights leaders for years to come.
The Scottsboro Case
The Scottsboro case, one of the most racially charged criminal trials in American history, began in March of 1931, when nine black youths ranging in age from 13 to 21 were arrested and charged with raping two white girls, Ruby Bates and Victoria Price, near Scottsboro, Alabama. The "Scottsboro boys" pleadednot guilty to the 20 indictments brought against them. Despite a spirited defense led by a coalition of Communists and civil rights leaders, an all-whitejury rejected their pleas. Eight of the boys were found guilty, while a mistrial was declared in the case 13-year-old Roy Wright. The eight convicted defendants were sentenced to death on 9 April 1931.
Given a racial climate overwhelmingly hostile to blacks, the verdicts came aslittle surprise. The jury ignored a great deal of evidence that tended to exonerate the defendants. Further complicating the defense was the appointmentby the court of Milo Moody, an inexperienced lawyer, as defense attorney in the case. A crowd of some 10,000 whites gathered outside the courthouse duringthe critical days of the trial, demonstrating and calling for vigilante justice.
The convictions likewise generated a passionate reaction worldwide. Labor leaders and radical organizations held rallies to protest the jury's verdict. Demonstrations were held as far away as Germany. Many of the leading intellectuals of the day, including Albert Einstein, signed a petition calling for therelease of the defendants. Eventually, these supporters were joined by one ofthe alleged victims, Ruby Bates, who recanted her testimony that she had been raped by the defendants. In November of 1932, the U.S. Supreme Court, in the case of Powell v. Alabama, overturned the convictions. The Court ruled that the Scottsboro boys had been denied due process of the law because the judge had been unacceptably casual in appointing their defense lawyer. Newtrials were set for all nine defendants.
Patterson's Case
Haywood Patterson was tried first. His defense attorneys asked that the casebe thrown out on the grounds that no blacks had been on the first jury. The judge dismissed this objection, and an all-white jury was chosen a second time. Again, despite substantial evidence that suggested otherwise, Patterson wasfound guilty. Dismayed by this seemingly willful disregard for the evidence,the judge set aside the jury's verdict and ordered a new trial. For a thirdtime, and again with a jury picked from a list that did not include blacks, Patterson was found guilty as charged. On 6 December 1933, Haywood Patterson was once again sentenced to death. He appealed the verdict to the Supreme Court of Alabama, which affirmed. Patterson then took his case before the U.S. Supreme Court.
In presenting his case, Patterson contended that there was a long-standing, systematic, and arbitrary exclusion of qualified blacks from jury service, based solely on their race, in violation of the Fourteenth Amendment of the U.S.Constitution. The state of Alabama argued on technical legal grounds that the Supreme Court had no jurisdiction over the case. Complicating matters further was the disposition of a second Scottsboro case, Norris v. Alabama(1935), argued purely on the merits and without the technical controversies.
Norris Case Decided
The case of Clarence Norris was decided first. On 1 April, Chief Justice Hughes delivered the opinion of the High Court, which held that the exclusion ofblacks from jury service was pervasive and deliberate. In rendering its decision, the Court relied on overwhelming evidence of tampering with jury rolls to indicate that blacks had been considered for jury service--when in fact they had not been. Hughes rejected the state of Alabama's contention that many blacks simply were not qualified for jury service. He wrote:
In the light of the testimony given by the defendant's witnesses, we find it impossible to accept such a sweeping characterization of the lack of qualifications of Negroes in Morgan County. It is so sweeping; and so contrary to the evidence . . . that it destroys the intended effect on the commissioner's testimony.He ordered the judgment of the appeals court reversed and anew trial ordered.
The decision in Norris v. Alabama was to prove pivotal for Haywood Patterson's case as well. While the Supreme Court agreed with the state of Alabama that Patterson's case should have been thrown out for technical legal violations, it was reluctant to send a man to death on the same evidence that hadbeen relied upon to grant Norris a new trial. "We cannot ignore the exceptional features of this case," Chief Justice Hughes wrote in his majority opinion. He concluded that the Alabama State Supreme Court should be given anotherchance to rule on the matter in light of the new evidence. Hughes also strongly hinted that the U.S. Supreme Court would take another look at the case ifPatterson's conviction were not overturned and a new trial granted.
In the end, Haywood Patterson was granted a new trial. But the result was thesame. In 1936, a jury composed of 13 whites and one black found him guilty.He was sentenced to 75 years in prison. He pursued another appeal, but this time the Supreme Court refused to hear his case. Patterson died in prison in 1952.
Impact
In the case of Patterson v. Alabama the Supreme Court attempted to correct what it perceived to be a gross injustice. In overlooking the technicaldefects of Patterson's case, the Court signaled that it would not let fidelity to arcane legal protocols prevent it from exonerating an individual from execution.
Related Cases
- Norris v. Alabama, 294 U.S. 599 (1935).
- Villa v. Van Schaick, 299 U.S. 152 (1936).
- People v. Wilson, 318 U.S. 688 (1943).
- Tinder v. United States, 345 U.S. 565 (1953).
Jury Nullification
Jury nullification takes place when a jury acquits a defendant even though the prosecution has proven the defendant's guilt beyond all reasonable doubt. The jury acquits the defendant because they disagree with the law whereby he or she is charged, and their acquittal serves as a form of protest.
The idea of jury nullification originated in England and gained popularity among rebellious American colonists, who used it as a means of registering their dissatisfaction with British rule. In the years leading up to the Civil War, jury nullification became popular with Abolitionists, who likewise used itto protest what they saw as an unjust system: the Fugitive Slave Law, which required the return of runaway slaves. During the late 1800s and early 1900s,white Southern juries, by refusing to convict white men guilty of killing blacks, used jury nullification for less idealistic purposes.
Despite its long and varied past, jury nullification did not gain popular attention until 3 October 1995, when a mostly African American jury in the O. J.Simpson murder case issued a "not guilty" verdict, an act which many saw asan attempt to address past racial injustices.
Sources
Fully Informed Jury Association (FIJA). http://www.primenet.com/~slack.
Further Readings
- Carter, Dan T. Scottsboro: A Tragedy of the American South. Baton Rouge, LA: Louisiana State Press, 1979.
- Chandler, Ralph C. The Constitutional Law Dictionary. Santa Barbara, CA: ABC-Clio, Inc., 1987.
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