People v. Currie
California Court of Appeal for the First District
87 Cal. App. 4th 225 (2001)
Currie (defendant), convicted of murder and firearm offenses, moved to quash the jury venire, arguing African-Americans (8.4% of the county population but only 4.6% of those appearing for jury duty) were unconstitutionally underrepresented; the trial court found he had not established a prima facie case of unconstitutional underrepresentation, and Currie appealed.
Whether a defendant can establish a prima facie case for unconstitutional underrepresentation of a group in a jury pool by showing the group is distinctive, its jury-pool representation is unfairly disproportionate to its community representation, and the underrepresentation results from systematic exclusion.