Hernandez v. Texas
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''Hernandez v. Texas'', 347 U.S. 475 (1954), was a landmark case, "the first and only Mexican-American civil-rights case heard and decided by the
United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
during the post-World War II period." In a unanimous ruling, the court held that Mexican Americans and all other nationality groups in the
United States The United States of America (U.S.A. or USA), commonly known as the United States (U.S. or US) or America, is a country primarily located in North America. It consists of 50 states, a federal district, five major unincorporated territori ...
have equal protection under the 14th Amendment of the
U.S. Constitution The Constitution of the United States is the supreme law of the United States of America. It superseded the Articles of Confederation, the nation's first constitution, in 1789. Originally comprising seven articles, it delineates the nation ...
. The ruling was written by Chief Justice Earl Warren. This was the first case in which Mexican-American lawyers had appeared before the Supreme Court.


Background

Peter Hernandez, a Mexican-American agricultural worker, was convicted for the 1951 murder of Cayetano “Joe” Espinosa, a man that he shot in cold blood at a bar in Edna, Texas. Hernandez's pro bono legal team, including Gustavo C. García, appealed the ruling, arguing that he was being discriminated against because there were no Mexicans in the jury that convicted him. They hoped to challenge what they described as "the systematic exclusion of persons of Mexican origin from all types of jury duty in at least seventy counties in Texas." They argued that Hernandez had the right to be tried by a jury of his peers under the 14th Amendment, but at the time, the 14th Amendment was a special civil rights protection intended for Black citizens. The State of Texas denied their claim, on the grounds that Mexicans were White and the 14th Amendment did not protect White nationality groups. Hernandez's legal team appealed, claiming that Mexican Americans, although White, were treated as a class apart and subject to social discrimination in Jackson County, where the case had been tried, and therefore were deserving of 14th Amendment protection. Their task was then to prove that Mexicans were being discriminated and were excluded from the grand jury and jury. The State of Texas never officially barred Mexicans from jury service, but Hernandez's defense lawyers demonstrated that, although numerous Mexican Americans were citizens and had otherwise qualified for jury duty in Jackson County, during the previous 25 years no Mexican Americans (or, more precisely, no one with a Hispanic surname) were among the 6,000 persons chosen to serve on juries. This resulted in Hernandez having been deprived of equal protection of the law under the Fourteenth Amendment, as juries were restricted by ethnicity. They appealed to the United States Supreme Court through a
writ of certiorari In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of an English prerogative writ, issued by a superior court to direct that the record of ...
. The legal team included García, Carlos Cadena and John J. Herrera of the
League of United Latin American Citizens The League of United Latin American Citizens (LULAC) is the largest and oldest Hispanic and Latin-American civil rights organization in the United States. It was established on February 17, 1929, in Corpus Christi, Texas, largely by Hispanics ...
, and James DeAnda and Cris Alderete of the G. I. Forum, both activist groups for civil rights for Mexican Americans. These were the first Mexican-American lawyers to represent a defendant before the US Supreme Court, which heard their arguments on January 11, 1954.


Ruling

Chief Justice Earl Warren and the rest of the Supreme Court unanimously ruled in favor of Hernandez, and required he be retried by a jury composed without discrimination against Mexican Americans. The court omitted the focus of race by declaring that other factors influence whether or not a group may need constitutional protection. To determine if discriminatory factors were present in Jackson County, the court investigated the treatment of Mexican Americans. They discovered a county-wide distinction between "white" and "Mexican" persons. At least one restaurant prominently displayed a sign that declared, "No Mexicans Served." Additionally, until a few years earlier, some Mexican American children attended segregated schools and were forced to drop out by fifth or sixth grade. These factors led the Supreme Court to their ultimate ruling that the Fourteenth Amendment protects persons beyond the racial classes of
white White is the lightest color and is achromatic (having no hue). It is the color of objects such as snow, chalk, and milk, and is the opposite of black. White objects fully reflect and scatter all the visible wavelengths of light. White o ...
or
black Black is a color which results from the absence or complete absorption of visible light. It is an achromatic color, without hue, like white and grey. It is often used symbolically or figuratively to represent darkness. Black and white ...
, and extends protection to nationality groups of white race as well.


Influence

The ruling was an extension of protection in the
Civil Rights Movement The civil rights movement was a nonviolent social and political movement and campaign from 1954 to 1968 in the United States to abolish legalized institutional racial segregation, discrimination, and disenfranchisement throughout the Unite ...
to nationality groups within the country and an acknowledgement that, in certain times and places, groups other than blacks (African Americans) could be discriminated against. The ultimate effect of this ruling was that the protection of the 14th Amendment was ruled to cover any national or ethnic groups of the United States for which discrimination could be proved. The oral arguments of this case have been lost. However, the United States Supreme Cour
docket sheet
an
letter from Justice Clark to Chief Justice regarding joining opinion
are available online.


See also

*
List of United States Supreme Court cases, volume 347 This is a list of all the United States Supreme Court cases from volume 347 of the ''United States Reports The ''United States Reports'' () are the official record ( law reports) of the Supreme Court of the United States. They include rulings, ...
* Jury trial


References


Further reading

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External links

*
''Hernandez v. State of Texas'' case
University of Texas School of Law archive * *
A Class Apart
''
American Experience ''American Experience'' is a television program airing on the Public Broadcasting Service (PBS) in the United States. The program airs documentaries, many of which have won awards, about important or interesting events and people in American his ...
, PBS - A landmark civil rights case. The little-known story of the Mexican American lawyers who took ''Hernandez v. Texas'' to the Supreme Court, challenging Jim Crow-style discrimination. Aired on
PBS The Public Broadcasting Service (PBS) is an American public broadcaster and non-commercial, free-to-air television network based in Arlington, Virginia. PBS is a publicly funded nonprofit organization and the most prominent provider of educat ...
on February 23, 2009. {{Civil Rights Movement United States Supreme Court cases United States Supreme Court cases of the Warren Court United States equal protection case law History of Latino civil rights 1954 in United States case law United States equal protection and criminal procedure case law United States racial discrimination case law Legal history of Texas