California Supreme Court
781 P.2d 537 (1989)
Edward Williams (defendant) was charged with first-degree murder. The murder occurred in the West Superior Court District of Los Angeles County (West District). The trial was scheduled to be held in the West District’s superior court. During jury selection, Williams moved to quash the jury venire, alleging that it unconstitutionally under-represented the African American population of Los Angeles County. The jury venire is the group of jurors available to sit on a case’s jury panel. The venire is selected from the population of the court district, rather than the entire county. According to the testimony of court staff, 11.4 percent of the eligible Los Angeles County population is African American, and 5.6 of the West District’s eligible population is African American. Williams argued that selecting the venire solely from the West District, rather than the full Los Angeles County, resulted in an unconstitutional underrepresentation of African American jurors. The trial court denied the motion, and Williams appealed. The California Court of Appeal affirmed but held that the analysis of underrepresentation should be focused on the population living within 20 miles of the particular courthouse where the trial is held. Williams then petitioned the California Supreme Court for review.
Rule of Law
Holding and Reasoning (Panelli, J.)
Concurrence (Kaufman, J.)
Dissent (Broussard, J.)
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