Summary of Edmonson v. Leesville Concrete Co. (1991)
Relevant Facts: Peremptory challenges by DF counsel at trial were questioned by PL, who asked the judge to get a racially neutral reason for the challenges to remove two black jurors of the three challenges in a civil trial. Judge denied, and this suit ensues.
Issue: Under constitutional law, is the Batson standard for questioning peremptory challenges in voi dire a violation when the civil trial court judge denies a motion by counsel for opposing counsel to articulate a reason for its peremptory challenge?
Holding: Yes. Batson challenges are extended to civil cases in addition to criminal cases.
Court’s Rationale/Reasoning: The Court takes a look at where the governmental sphere ends and the private sphere begins in implementing race discrimination practices to the States.
Application of the Lugar standard satisfied the first prong. Peremptory challenges are federally mandated, even when applied in state court (federal statute). As to the second prong, the Court, in determining whether a particular action of course of conduct is governmental in character, it is relevant to examine the following: (a) the extent to which the actor relies on governmental assistance and benefits, (b) whether the actor is performing a traditional governmental function, and (c) whether the injury caused is aggravated in a unique way by the incidents of government authority. The Court finds that the challenges by the DF in the trial court was pursuant to a course of state action.
There is state action when private parties make extensive use of state procedures with the overt, significant assistance of state officials; this is true here. Congress has established qualifications and procedure for juries, and the states are regulated to follow this.
Of course, jury procedure is traditional governmental function, as illustrated by the 7th Amendment, as well as all the civil procedure out there.
As to the injury, the Court finds that permitting a denial of scrutiny by opposing counsel to a peremptory challenge, that the Federal system would be severely harmed as well. Race discrimination in the courtroom raises serious questions as to the fairness of the proceedings conducted there. Racial bias mars the integrity of the judicial system and prevents the idea of a democratic gov’t from becoming a reality.
(as to third party, the Court said the opposing counsel could assert the rights of the excluded jurors by evoking a the Batson challenge)
Rule: Lugar standard for challenging a State’s procedure in court: (1) did the claimed constitutional deprivation result from the exercise of a right or privilege having its source in state authority? And (2) could the private party charged with the deprivation be described in all fairness as a state actor?
Important Dicta: This is a case of first impression.