Strauder v. West Virginia

Following is the case brief for Strauder v. West Virginia, 100 U.S. 303 (1880)

Case Summary of Strauder v. West Virginia:

  • West Virginia had a law that declared that only white men may serve on juries.
  • Strauder, an African-American who was indicted for murder, sought to remove his trial to federal court because West Virginia’s law was unconstitutional.
  • The state trial court denied Strauder relief.  Strauder was convicted and sentenced.  The West Virginia Supreme Court affirmed.
  • The U.S. Supreme Court reversed the West Virginia Supreme Court.  It held that West Virginia’s law violated the Equal Protection Clause of the Fourteenth Amendment.

Strauder v. West Virginia Case Brief

Statement of the Facts:

West Virginia had a law on its books that allowed only white males over the age of 21 to serve on grand and petit juries.  Strauder, an African-American man, was indicted for murder in state court in West Virginia.  Before trial, Strauder sought to have his trial moved to federal court, arguing that an all-white jury violated his rights under the Constitution.

Procedural History:

  • The state trial court denied Strauder’s request. Strauder was then convicted and sentenced.
  • The West Virginia Supreme Court affirmed the trial court’s decision.
  • The U.S. Supreme Court took the case on a writ of error.

Issue and Holding:

Does requiring that only white men serve on grand and petit juries violate the Equal Protection Clause of the Fourteenth Amendment?  Yes.

Judgment:

The decision of the West Virginia Supreme Court is reversed and remanded.

Rule of Law or Legal Principle Applied:

The Equal Protection Clause of the Fourteenth Amendment prohibits a government from discriminating on who can serve on grand and petit juries based on race.

Reasoning:

The language, purpose, and spirit of the Fourteenth Amendment was to give African-Americans — who had been recently emancipated from the terrible institution of slavery — the same rights and privileges as whites in the United States.  That means that not only did people of color gain the privileges of citizenship, but also the States lost the power to withhold from people of color the equal protection of the laws.

The West Virginia law, allowing only whites to serve on juries, runs directly counter to the Fourteenth Amendment’s mandate.  West Virginia’s law “is an impediment to securing to individuals of the [African-American] race that equal justice which the law aims to secure to all others.”  Therefore, the judgment of the West Virginia Supreme Court is reversed.

Justices Field and Clifford dissented with no opinion, relying on Justice Field’s opinion in Ex parte Virginia, 100 U.S. 339 (1879).

Significance:

Strauder v. West Virginia is significant because it was one of the first cases to squarely confront a racially discriminatory law based on the newly enacted Fourteenth Amendment, and following the recently ended Civil War.  While the holding that government-sanctioned racial discrimination is unconstitutional seems obvious by today’s standards, back in 1880 it was groundbreaking.  In fact, the Court’s opinion was prescient in predicting the kind of racially charged backlash that would result from the notion of equal protection for African-Americans embodied in the Fourteenth Amendment.

Student Resources:

Read the Full Court Opinion

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