Strauder v. West Virginia case brief

Strauder v. West Virginia case brief summary
100 U.S. 303 (1880)

CASE SYNOPSIS

Defendant appealed from a judgment of the Supreme Court of Appeals of the State of West Virginia, which affirmed defendant's conviction for murder. The trial court convicted defendant after denying defendant's petition for removal to federal court.

CASE FACTS
Defendant, plaintiff in error, was convicted of murder. Prior to trial, he petitioned for removal under U.S. Rev. Stat. § 641, which provided for removal when individuals in state court were denied their civil rights. Defendant objected to the fact that black men were ineligible for jury duty under 1873-73 W. Va. Act 102.


DISCUSSION

• The court held that the state statute unconstitutionally discriminated on the basis of race and that it amounted to a denial of equal protection. 
• The court further ruled that the congressional power to enforce U.S. Constitutional Amendment XIV gave Congress sufficient authority to enact the federal removal statute. 
• The court concluded that Congress had the power to authorize removal when a right under federal law or the U.S. Constitution was involved. 
• Therefore, it was error for the state trial court to proceed to trial after defendant filed for removal based on a denial of equal protection.

CONCLUSION
The court reversed the judgment of the state supreme court and remitted the case with instructions to reverse the judgment of the state trial court.


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