Castaneda v. Partida

Rodrigo Partida (defendant) was charged with burglary of a private residence with intent to rape in Hidalgo County, Texas. Partida was convicted and sentenced to eight years in prison. Partida subsequently filed a habeas corpus action against Castaneda (plaintiff), the sheriff of Hidalgo County. Among other claims, Partida contended that discrimination in the grand-jury selection process violated his constitutional right to equal protection. Partida’s argument established that 79.1 percent of the population of Hidalgo County was Mexican American according to the 1970 United States Census. However, over an 11-year period, just 39 percent of all persons summoned for grand-jury service were Mexican American. The United States Supreme Court had previously held similar differences to indicate a prima facie case of discrimination, such as a gap between 27 percent of citizens being African American in a Georgia jurisdiction in 1967, whereas only 9 percent of the grand-jury panel was African American. In two other Georgia cases from the same era, gaps of 24.4 percent on African American tax lists versus 4.7 percent grand-jury participants and 19.7 percent on tax lists versus 5 percent grand-jury participants had also been held to establish prima facie cases of discrimination. An appellate court ruled for Partida, and the government appealed to the Supreme Court.