Hernandez v. Texas

Following is the case brief for Hernandez v. Texas, 347 U.S. 475 (1954)

Case Summary of Hernandez v. Texas:

  • Hernandez was indicted for murder by a grand jury, and he was ultimately convicted and sentenced to life in prison.
  • He moved to quash his indictment and trial jury panel, alleging that the county that charged him systematically excluded Mexicans from serving as jury commissioners, grand jurors, and petit jurors.
  • The Texas trial court denied the motion, and the Texas Court of Criminal Appeals affirmed the denial.
  • The U.S. Supreme Court reversed, holding that Mexicans were systematically denied the ability to serve as jurors in violation of the Equal Protection Clause.

Hernandez v. Texas Case Brief

Statement of the Facts:

Pete Hernandez was indicted, and ultimately convicted and sentenced, for the murder of Joe Espinosa.  Prior to and at trial, Hernandez moved to quash the indictment and his trial jury panel.

In his motion, he claimed that persons of Mexican descent were systematically excluded from serving as grand jurors or trial jurors.  Therefore, he claimed that he was deprived, as a Mexican-American, of equal protection because a class of eligible people were excluded from jury service on the basis of their Mexican heritage.

Procedural History:

  • The trial court denied the motion, and the Texas Court of Criminal Appeals passed on the equal protection issue presented.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Is it a denial of equal protection to try a defendant of a particular race when all people of his or her race are excluded by the State from serving on grand juries and trial juries?  Yes.

Judgment:

The decision of the Texas Court of Criminal Appeals is reversed.

Rule of Law or Legal Principle Applied:

A person has the constitutional right to be indicted and tried by juries from which all members of his class are not systematically excluded.

Reasoning:

In this unanimous decision, the Court reasoned that previous cases made it clear that African-American’s could not be excluded from the jury pool of potential grand jurors or trial jurors if there were eligible African-Americans in the population.  The same reasoning from those cases applies here.  Moreover, the State of Texas’ argument that equal protection only applies to discrimination against African-Americans is incorrect.

Hernandez established, first, that people of Mexican descent constituted a separate class in his county, distinct from white people.  In fact, there were many examples of discrimination against Mexicans in Hernandez’s county, such as a public bathroom for whites and a separate one for African-Americans and Mexican-Americans.

Second, Hernandez proved discrimination by showing that 14% of the population in the county had Mexican or Latin American surnames but no person with those surnames served on a jury in the last 25 years.  The State’s rebuttal testimony from jury commissioners, claiming that they did not discriminate against Mexicans, was unpersuasive.

Significance:

Hernandez v. Texas is an important decision because it made clear that the Equal Protection Clause of the Fourteenth Amendment did not just apply to discrimination against African-Americans.  Rather, it applies to discrimination based on race and national origin.

Student Resources:

Full Text of Opinion

 

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