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Arnold v. North Carolina

Citations: 12 L. Ed. 2d 77; 84 S. Ct. 1032; 376 U.S. 773; 1964 U.S. LEXIS 1490Docket: 572

Court: Supreme Court of the United States; April 6, 1964; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

In this case, the petitioners, two African American individuals, challenged their murder convictions, arguing that their indictments were tainted by the systematic exclusion of Black individuals from the grand jury. The Supreme Court of North Carolina upheld the convictions, finding no evidence of racial exclusion. However, the U.S. Supreme Court reviewed the case, noting the significant disparity in racial representation on the grand jury, with only one Black juror having served in 24 years despite the racial demographics of the county. The petitioners established a prima facie case of denial of equal protection, supported by precedents from Norris v. Alabama and Eubanks v. Louisiana. The U.S. Supreme Court found the State failed to counter this prima facie case with any evidence, thereby reversing the lower court's judgment. The decision underscored the constitutional guarantee of equal protection in jury selection, emphasizing the need for fair representation of racial minorities in the judicial process. Consequently, the indictments against the petitioners were quashed, highlighting the judiciary's role in safeguarding civil rights against discrimination in legal proceedings.

Legal Issues Addressed

Burden of Proof in Equal Protection Claims

Application: The Court highlighted the lack of evidence from the State to refute the prima facie case made by the petitioners, thus failing to meet the burden of proof.

Reasoning: The Court noted the uncontradicted testimony of the petitioners and the lack of evidence from the State to counter these claims.

Equal Protection in Jury Selection

Application: The U.S. Supreme Court found that the petitioners demonstrated a prima facie case of denial of equal protection due to the systematic exclusion of Black individuals from the grand jury.

Reasoning: The U.S. Supreme Court determined that the petitioners established a prima facie case of denial of equal protection under the law, citing precedents such as Norris v. Alabama and Eubanks v. Louisiana.

Systematic Exclusion of Racial Minorities from Jury Duty

Application: The Court recognized the significant disparity in the representation of Black individuals on the grand jury as evidence of systematic exclusion.

Reasoning: Petitioners argued that the exclusion warranted quashing the indictment, presenting evidence indicating a significant disparity in representation: 12,250 white individuals compared to 4,819 Black individuals in the county, and only one Black juror having served on a grand jury in 24 years.