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Coleman v. Alabama
Citations: 12 L. Ed. 2d 190; 84 S. Ct. 1152; 377 U.S. 129; 1964 U.S. LEXIS 1364Docket: 583
Court: Supreme Court of the United States; May 4, 1964; Federal Supreme Court; Federal Appellate Court
Petitioner John Coleman, a Black man sentenced to death for the murder of a white man, challenged his conviction on the grounds of Due Process and Equal Protection violations under the Fourteenth Amendment, asserting that Black individuals were systematically excluded from the grand and petit juries in his case. The State contended that this claim was raised too late, only appearing in a motion for a new trial. The trial judge allowed the motion but rejected all inquiries regarding jury discrimination, resulting in a denial of the motion. The Alabama Supreme Court upheld the conviction, determining that the claim was unsupported by evidence. Although the petitioner did not contest Alabama's procedural rules requiring pre-trial objections to jury composition, he did attempt to present evidence of discrimination during his motion for a new trial. The trial judge permitted testimony but sustained objections to questions about systematic exclusion, emphasizing that the issue had not been raised earlier. The Alabama Supreme Court acknowledged that the petitioner had been given a chance to provide evidence but found that he failed to substantiate his allegations, aside from an affidavit from his mother noting that both juries consisted entirely of white members. The motion for a new trial suggested a pattern of exclusion that could warrant a new trial if proven. Despite the failure to raise the issue pre-trial, the Alabama Supreme Court reviewed the merits of the discrimination claim and concluded that the petitioner did not meet the burden of proof required to demonstrate racial discrimination in jury selection. The court determined that the appellant did not provide sufficient proof regarding the systematic exclusion of Black individuals from jury rolls in Greene County, leading to the conclusion that the appellant could not raise this complaint. The Supreme Court of Alabama addressed the appellant's constitutional claim on its merits, ultimately finding that the conviction and death sentence were not in violation of the protections afforded by the U.S. Constitution. However, since the appellant was not allowed to present evidence supporting his claim, the judgment affirming the conviction was reversed. The court emphasized that the appellant is entitled to present his allegations of systematic exclusion in court. The case was remanded to the Supreme Court of Alabama for further proceedings consistent with this ruling. During the trial, objections were sustained against questions regarding the presence of Black jurors in both the grand and petit juries, indicating that these issues should have been raised through formal motions. The court referenced legal precedents, including *Carter v. Texas*, to support the decision to reverse the judgment. The appellate court retains the discretion to review testimony that may have prejudiced the appellant's rights, allowing for a new trial if the verdict is found to be unjust, regardless of whether a prior objection was made.