Johnson v. California, 545 U.S. 162 (2005)
Primary Holding
To establish a prima facie case of racial discrimination in jury selection under Batson v. Kentucky, a defendant does not need to show that it is more likely than not that the peremptory challenges were based on impermissible group bias; rather, the defendant must only demonstrate that the circumstances raise an inference of discrimination.
In the case of Johnson v. California, a man named Jay Shawn Johnson argued that he was unfairly tried because the prosecutor removed black jurors from the jury without good reason, which could suggest racial bias. The Supreme Court decided that a defendant doesn't need to prove that discrimination was more likely than not; they only need to show that there are enough signs of potential bias to raise suspicion. This ruling helps protect consumers by ensuring that everyone has the right to a fair trial with a jury that represents diverse backgrounds, making it relevant if someone feels they are facing discrimination in jury selection or similar situations.
AI-generated plain-language summary to help you understand this case
The California Department of Corrections maintained a policy under which new inmates were held in reception centers for up to 60 days after their arrival. Prison authorities used that time to determine their assignments. During this period, according to a prisoner named Johnson, prison officials used race to assign temporary cell mates. Once permanent cells were found, race no longer was used. Johnson argued that this practice violated equal protection requirements, but the prison authorities responded that it was necessary to prevent gang violence.
Whether to establish a prima facie case under Batson v. Kentucky, the objector must show that it is more likely than not that the other party’s peremptory challenges, if unexplained, were based on impermissible group bias.
The judgment is reversed.
This decision extends beyond the context of prisons, which are often a special environment for analyzing constitutional issues. The Court departed from precedent in finding that segregation should be treated the same as other forms of racial distinctions. Strict scrutiny is appropriate, but it is not unconstitutional per se.
- Court
- Supreme Court
- Decision Date
- April 18, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Stevens
- Damages Awarded
- N/A
- Data Quality
- high
Johnson v. California, 543 U.S. 499 (2005)
Consumer WonStrict scrutiny is the appropriate standard of review for an equal protection challenge to a policy of racially segregating prisoners in California's reception centers, as such segregation based on race is subject to heightened scrutiny under the Fourteenth Amendment.
Miller-El v. Dretke, 545 U.S. 231 (2005)
Consumer WonProsecutors' use of peremptory strikes in jury selection based on race violates the Equal Protection Clause of the Fourteenth Amendment, and a defendant is entitled to relief if they can demonstrate that such discrimination occurred.
Wilkinson v. Dotson, 544 U.S. 74 (2005)
Consumer WonPrisoners may bring actions under 42 U.S.C. §1983 to challenge the constitutionality of state parole procedures, rather than being required to seek relief exclusively through federal habeas corpus statutes.
Johnson v. United States, 544 U.S. 295 (2005)
Consumer LostThe period for the 1-year statute of limitations under 28 U.S.C. §2255 begins when a petitioner receives notice of the order vacating a prior conviction used to enhance their federal sentence, provided that the petitioner has pursued the vacatur with due diligence in state court.