## Facts

- Thaddeus Donald Edmonson, a Black construction worker, was injured at Fort Polk, Louisiana, when a truck allegedly rolled backward and pinned him against equipment.
- Edmonson sued his employer, Leesville Concrete Co., in federal court for negligence and demanded a jury trial.
- During voir dire, Leesville used two of three peremptory challenges to strike Black prospective jurors.
- Edmonson objected and sought a race-neutral explanation under the rule barring race-based strikes in jury selection; the district court refused, reasoning the rule did not apply in civil cases.
- The seated jury consisted of 11 white jurors and 1 Black juror.
- The jury found for Edmonson and assessed $90,000 in damages but attributed 80% fault to Edmonson, yielding an $18,000 net award.
- On appeal, a Fifth Circuit panel reversed, but the en banc Fifth Circuit affirmed the district court.
- The Supreme Court granted review to decide whether constitutional limits on race-based peremptory challenges apply to private parties in civil trials.

## Issues

1. Whether a private litigant’s exercise of peremptory challenges in a federal civil jury trial constitutes state action subject to constitutional limits.
2. Whether excluding prospective jurors on account of race through peremptory challenges in a civil trial violates the equal protection component of the Fifth Amendment’s Due Process Clause.
3. Whether a civil litigant has standing to assert the equal protection rights of excluded jurors.

## Decision

- The Supreme Court reversed the Fifth Circuit.
- The Court held that a private party’s use of peremptory challenges in a civil trial is attributable to the government and therefore constitutes state action.
- The Court held that race-based peremptory strikes in civil trials violate the equal protection rights of the excluded jurors under the Fifth Amendment.
- The Court confirmed that a litigant may raise the equal protection claims of prospective jurors excluded on the basis of race.

## Legal Principles

- The Fifth Amendment’s Due Process Clause contains an equal protection component that bars the federal government from racial discrimination, including in jury selection.
- Under the state-action inquiry, peremptory challenges are traceable to governmental authority because they exist only by statute and operate solely within a government-administered jury system.
- A private litigant’s peremptory strike is fairly attributable to the government because the court controls voir dire and gives practical effect to the exclusion from jury service.
- Prospective jurors possess an equal protection right not to be excluded from jury service on account of race.
- Constitutional limits on race-based peremptory challenges apply in civil as well as criminal jury trials, requiring race-neutral justifications when a prima facie case of discrimination is shown.

## Conclusion

The Court held that when private civil litigants exercise peremptory challenges to exclude jurors because of race, they engage in state action and violate the excluded jurors’ equal protection rights under the Fifth Amendment, making race-based strikes subject to judicial scrutiny and requiring race-neutral explanations.


Edmonson v. Leesville Concrete Co., 500 U.S. 614 (1991)