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J. E. B. v. Alabama ex rel. T. B.

Citation: 511 U.S. 127Docket: No. 92-1239

Court: Supreme Court of the United States; April 19, 1994; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

The Supreme Court addressed the application of the Equal Protection Clause of the Fourteenth Amendment to gender-based peremptory challenges in jury selection. The case arose from a paternity and child support proceeding in Alabama, where the State used nine out of ten peremptory challenges to exclude male jurors, resulting in an all-female jury. The petitioner argued that this practice violated the Equal Protection Clause, similar to racial discrimination addressed in Batson v. Kentucky. The trial court's decision to empanel the all-female jury was upheld by the Alabama Court of Civil Appeals; however, the Supreme Court granted certiorari to resolve the issue. The Court held that gender discrimination in jury selection is unconstitutional, emphasizing the need for heightened scrutiny of gender-based classifications. It rejected the respondent's justification based on gender stereotypes, highlighting their harmful impact on the justice system. The decision reversed the lower court's ruling, mandating nondiscriminatory jury selection for both genders, and reinforcing the principle of equal protection under the law. The ruling aligns with historical efforts to eliminate gender-based exclusion from civic duties, including jury service, and underscores the importance of an impartial and representative jury.

Legal Issues Addressed

Constitutional Mandate for Nondiscriminatory Jury Selection

Application: The decision underscores the constitutional requirement for nondiscriminatory jury selection processes, affirming the rights of jurors and litigants.

Reasoning: Jurors possess a right to non-discriminatory selection processes, a principle applicable to both genders.

Equal Protection Clause and Peremptory Challenges

Application: The Court extends the principles established in Batson v. Kentucky to prohibit gender-based discrimination in peremptory challenges during jury selection.

Reasoning: The Court held that intentional gender discrimination by state actors is unconstitutional under the Equal Protection Clause, emphasizing that such discrimination perpetuates harmful stereotypes regarding gender capabilities.

Heightened Scrutiny for Gender-Based Classifications

Application: The Court applies heightened scrutiny to gender-based classifications in jury selection, requiring an exceedingly persuasive justification for such discrimination.

Reasoning: Under equal protection jurisprudence, such classifications require 'an exceedingly persuasive justification' to withstand constitutional review.

Historical Context of Gender Discrimination in Jury Service

Application: The opinion outlines the historical exclusion of women from jury service and the perpetuation of stereotypes that justified such exclusion.

Reasoning: Discrimination based on gender in the use of peremptory challenges has emerged as a notable issue in the legal landscape, particularly since women were historically barred from jury service until the 20th century.

Impact of Stereotypes in Jury Selection

Application: The Court rejects the use of stereotypes as a basis for peremptory challenges, highlighting that such stereotypes undermine the integrity of the jury system.

Reasoning: Gender-based peremptory challenges cannot be defended by relying on stereotypes that the law seeks to eliminate.