## Facts

- James Ross, Jr., a Black defendant, was tried in Massachusetts with two Black co-defendants for armed robbery and related violent offenses.
- The victim was a white Boston University uniformed security guard.
- Before voir dire, defendants requested that the judge ask prospective jurors questions specifically directed to racial prejudice, and also requested questions about affiliations with law-enforcement agencies.
- The trial judge denied the request for race-specific questions and instead asked only general questions about bias and impartiality as required by Massachusetts law.
- Ross was convicted; the state appellate courts affirmed.
- Ross sought federal habeas relief; the First Circuit granted relief, reading prior precedent to require inquiry into racial prejudice.
- The Supreme Court granted certiorari to review whether the Constitution required race-focused voir dire in these circumstances.

## Issues

1. Whether due process entitled the defendant to require a voir dire question specifically directed to racial prejudice.
2. Whether prior precedent created a universal constitutional rule requiring race-specific voir dire whenever defendant and victim are of different races.

## Decision

- The Supreme Court reversed the First Circuit’s grant of habeas relief and left the state conviction intact.
- The Court held that the Constitution did not require race-specific voir dire on these facts.
- The Court ruled that prior precedent did not establish a universal requirement for race-focused questioning in interracial criminal trials.
- The Court concluded that the general inquiries into bias and impartiality were constitutionally sufficient absent special circumstances indicating a substantial risk that racial prejudice would go undiscovered.

## Legal Principles

- Due process requires an impartial jury, but that obligation generally may be satisfied without questioning directed to a specific prejudice feared by the defendant.
- Race-specific voir dire is constitutionally required only when case-specific circumstances create a significant risk that racial prejudice will affect the trial and that general questions will be inadequate.
- The mere fact of an interracial crime, without more, does not itself compel a constitutionally mandated inquiry into racial prejudice.

## Conclusion

The Court held that, absent special circumstances comparable to those in earlier precedent, a trial court does not violate due process by refusing to ask race-specific voir dire questions and instead relying on general inquiries into juror bias and impartiality.


Ristaino v. Ross, 424 U.S. 589 (1976)