Williams v. Superior Court
California Supreme Court
781 P.2d 537 (1989)
Edward Williams (defendant) was charged with first-degree murder in the West Superior Court District of Los Angeles County, where his trial was set. During jury selection he moved to quash the jury venire (the pool jurors are drawn from), arguing it underrepresented African Americans. Testimony showed African Americans made up about 11.4 percent of eligible county residents but only about 5.6 percent of the West District's eligible residents. Williams argued that drawing jurors only from the West District, rather than the whole county, was unconstitutional. The trial court denied the motion; the Court of Appeal affirmed but suggested a 20-mile radius standard. Williams sought review.
Whether the judicial district, rather than the entire county, is the relevant community for determining whether a jury venire represents a fair cross-section of the community under the Sixth Amendment.