Edmonson v. Leesville Concrete Co. Case Brief
Summary of Edmonson v. Leesville Concrete Co. (1991)
Federal trial during voir dire. Δ, a private company, exercises preemptory strikes to exclude blacks from the jury (employment discrimination case). Held: The attorney is not completely a private actor b/c he has the assistance from the government. Govt facilitates the jury and trial system + trials by jury are a traditional government function.
a. Justice Kennedy’s State Action: Edmonson Synthesis
(1) Was the Constitutional deprivation the result of the exercise of a right/privilege w/ its source in state authority? (here, yes, only have rt of preemptories if in a court)
(2) Can a private party fairly be described as a state actor?
(a) Does it rely on government aid/benefits?
(b) Is it a traditional governmental function? (marsh)
(c) Do incidents of governmental authority uniquely aggravate the injury?