Tuesday, November 5, 2013

Edmonson v. Leesville Concrete Co. case brief

Edmonson v. Leesville Concrete Co. case brief summary
500 U.S. 614 (1991)

Petitioner worker appealed an order from the United States Court of Appeals for the Fifth Circuit denying the worker's request that respondent company state a race-neutral reason when using peremptory challenges to dismiss potential jurors in the worker's civil action against the company.

The worker filed suit against the company for negligence. At trial, the worker's request that the company articulate race-neutral reasons for using its peremptory challenges was denied. On appeal, the judgment was affirmed. The court held that use of peremptory challenges in civil suits did not constitute state action and did not implicate constitutional guarantees.


  • The Supreme Court reversed, holding that peremptory challenges were only permitted when a statute or law allowed them. 
  • Use of peremptory challenges involved significant state action because they were not exercised without overt, significant assistance from the trial court. 
  • The trial court summoned and discharged jurors and exerted control over the voir dire system. 
  • The use of peremptory challenges involved the traditional government function of conducting a trial. 
  • The worker had standing to assert the rights of potential jurors because the worker was directly injured by the dismissals, and the task of jurors asserting their own rights was daunting.


The Court reversed, holding that significant state action existed in a civil trial when the private company used peremptory challenges to dismiss jurors based on race, and the worker had standing to file suit.

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