Patterson c.Alabama

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United States Supreme Court Case

Patterson c.Alabama
Argument from February 15 to 18, 1935
Decided on April 1, 1935
Full name of the case Patterson c.Alabama
Citations 294 US. 600 (Suite)

55 S. Ct. 575; 79 LED. 1082
Case history
Before Patterson v. State, 229 Ala. 270, 156 So. 567 (1934); cert. granted, 293 US. 554 (1935).
Holding
African-American defendant denied due process if jury excludes African-Americans.
Membership of the Court
Chief Justice
Charles E. Hughes
Associate judges
Willis Van Devanter · James C. McReynolds
Louis Brandeis · George Sutherland
Pierce Butler · Harlan F. Stone
Owen Roberts · Benjamin N. Cardozo
Case opinion
Majority Hughes, joined by Van Devanter, Brandeis, Sutherland, Butler, Stone, Roberts, Cardozo
McReynolds took no part in the consideration or decision of the case.
Laws applied
US Const. amended. I, XIV

Patterson c.Alabama, 294 US 600 (1935), was a United States Supreme Court case which ruled that an African American defendant was denied due process rights if the panel of jurors excluded African Americans.

Fond

This case was the second landmark decision stemming from the Scottsboro Boys trial (the first was the 1932 case, Powell c.Alabama). Haywood Patterson, along with several other African-American defendants, was tried for raping two white women in 1931 in Scottsboro, Alabama. The trials were rushed, there were hardly any lawyers, and no African-Americans were admitted to the jury. All of the defendants, including Patterson, have been convicted. The Communist Party of the United States assisted the defendants and appealed to the Supreme Court, which overturned the convictions in 1932 (in the Powell c.Alabama decision) due to lack of legal advice.

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A second round of trials then took place in Decatur, Alabama. Despite the lack of evidence, the jury sentenced Patterson to death in the electric chair. Judge James Edwin Horton set aside the verdict and a third trial was held in 1933. The third trial also resulted in a verdict of the death penalty. No African-American was present on any of the juries, and none was ever considered a juror in Alabama. That decision was appealed to the Supreme Court on the grounds that the absence of African Americans from the jury panel denied the defendants due process.

The Supreme Court accepted and the convictions were overturned.

In 1936 the defendants were tried, some for the fourth time, again for rape. In this trial, the verdicts were again guilty, but the sentences were long prison terms, rather than the death penalty.

Notes and references

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