## Facts

- Edward Williams, a Black criminal defendant, was charged with first-degree murder of a White victim in Los Angeles County.
- The charged homicide occurred in the West Superior Court District, and trial was set in the West District courthouse.
- Los Angeles County selected jury venires by superior court judicial district rather than from a single countywide pool.
- Williams moved pretrial to quash the West District venire, asserting unconstitutional underrepresentation of Black prospective jurors and requesting transfer to another district with a higher Black population.
- Evidence indicated Black persons comprised about 11.4% of the county’s jury-eligible population but about 5.6% of the West District’s jury-eligible population.
- The trial court denied the motion; the Court of Appeal denied relief and proposed defining “community” as a 20-mile radius around the courthouse.
- Williams sought extraordinary writ relief in the California Supreme Court, claiming violation of federal and state fair-cross-section rights.

## Issues

1. For the fair-cross-section requirement, what is the proper definition of “community” in a county that draws venires by judicial district: the county, the judicial district, or an area within 20 miles of the courthouse?
2. Does drawing venires by superior court judicial district in Los Angeles County violate the right to an impartial jury drawn from a fair cross-section of the community on the record presented?

## Decision

- The California Supreme Court denied writ relief.
- The Court held the relevant “community” for fair-cross-section analysis is the superior court (judicial) district.
- The Court rejected both a countywide baseline and a 20-mile-radius baseline for defining “community” in this context.
- The Court concluded Williams did not establish a prima facie fair-cross-section violation because the showing relied on an incorrect denominator and did not demonstrate systematic exclusion.

## Legal Principles

- A prima facie fair-cross-section claim requires proof that: (1) the excluded class is a distinctive group; (2) its representation in venires is not fair and reasonable compared to its share of the relevant community; and (3) the underrepresentation is due to systematic exclusion in the selection process.
- When venires are lawfully drawn by judicial district, the relevant comparison for underrepresentation is between venire composition and the jury-eligible population of that judicial district.
- Geographic variation in demographic composition among judicial districts, without evidence that selection mechanics within the district cause the disparity, does not constitute “systematic exclusion.”
- The Constitution permits district-based jury pools when districts are created for legitimate administrative and geographic reasons and the selection method within the district is free from discriminatory exclusion.

## Conclusion

The court upheld Los Angeles County’s practice of drawing juries by superior court judicial district and ruled that fair-cross-section “community” is the judicial district itself; absent proof that district selection procedures systematically exclude a distinctive group relative to that district’s eligible population, demographic differences between districts and the county do not establish a constitutional violation.


Williams v. Superior Court, 49 Cal. 3d 736, 781 P.2d 537 (Cal. 1989)