Law School Case Brief
Edmonson v. Leesville Concrete Co. - 500 U.S. 614, 111 S. Ct. 2077 (1991)
When the Supreme Court of the United States considers the state-action question in the context of a due process challenge to a state's procedure allowing private parties to obtain prejudgment attachments, the Court asks first whether the claimed constitutional deprivation resulted from the exercise of a right or privilege having its source in state authority; and second, whether the private party charged with the deprivation could be described in all fairness as a state actor.
Plaintiff Thaddeus Donald Edmonson, an African-American construction worker who had been injured in a job-site accident at a federal enclave, filed a negligence action in federal district court against defendant Leesville Concrete Co., Inc., ("Leesville"). When Leesville used two of its three peremptory challenges to remove African-American prospective jurors, the district court rejected Edmonson's objections based on Batson v. Kentucky and expressed the view that Batson did not apply in civil proceedings. Eventually, a jury consisting of 11 Caucasian jurors and one African-American juror returned a verdict for Edmonson and assessed his total damages at $ 90,000, but attributed 80 percent of the fault to Edmonson's own contributory negligence, so that the net award was only $ 18,000. On Edmonson's appeal, a panel of the United States Court of Appeals for the Fifth Circuit reversed and remanded, finding that peremptory challenges could not be used in a civil trial for the purpose of excluding jurors based on race. On rehearing en banc, however, the appellate court affirmed the district court's judgment, holding that use of peremptory challenges in civil suits did not constitute state action and did not implicate constitutional guarantees. Edmonson was granted a writ of certiorari.
Did the district court err by allowing Leesville's use of peremptory challenges in Edmonson's civil action?
The Supreme Court of the United States reversed the appellate court's judgment and remanded the case for further proceedings. The Court ruled that under the equal protection component of the due process clause of the Constitution's Fifth Amendment, a private litigant in a civil case that originated in a federal district court could not use peremptory challenges to exclude prospective jurors on account of their race. The Court noted that peremptory challenges were only permitted when a statute or law allowed them, and that use of peremptory challenges involved significant state action because they were not exercised without overt, significant assistance from the trial court. The Court also ruled that Edmonson had standing to assert the rights of potential jurors because he was directly injured by the dismissals, and the task of jurors asserting their own rights was daunting. On remand, a determination had to be made as to whether Edmonson established a prima facie case of racial discrimination under the approach set forth in Batson, such that Leesville would be required to offer race-neutral explanations for its peremptory challenges.
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