Petition — Lopez v. United States

Gupreme Cour, U. \)

FILED

MAR 23 979

CLERK

IN THE ;

Supreme Court of the United States

OCTOBER TERM, 1978

No. th

— 98-147

MARY FRANCIS LOPEZ,

Petitioner,

versus

UNITED STATES OF AMERICA,

Respondent.

PETITION FOR A WRIT OF CERTIORARI

TO THE UNITED STATES COURT OF APPEALS

FOR THE FIFTH CIRCUIT

MARK SMITH & ASSOCIATES

1220 Broadway, Suite 1820

Lubbock, Texas 79401

Attorney for Petitioners

SCOFIELDS' QUALITY PRINTERS, P. O. BOX 53096, N. O., LA. 70153 - 504/822-1611

William. Francis Huffman

316 Hannes

Silver Springs, Maryland 20901

——~o—_______.——

TABLE OF CONTENTS

Page

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CONSTITUTIONAL PROVISIONS _#IN-

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Course of Proceedings and Disposition in

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REASONS FOR GRANTING THE WRIT ....... 5

BF a rn n 11

Be Ae Bk SE rr 12

APPENDIX A — Judgment and

Probation/Commitment Order ............... la

APPENDIX B — Opinion of the United States

Court of Appeals for the Fifth Circuit ........ 3a

APPENDIX C — Order Denying Petition for

ERR Suey ay <5 CP es a ee 6a

APPENDIX D — Table of Ratios of Spanish

Surnames called for Petit Jury Service in the

8a

Lubbock Division, 8/71-6/78 .................

TABLE OF AUTHORITIES

CASES:

Alexander v. Louisiana, 405 U.S. 625, 92S.Ct.

Ay Oe RU POO ROUTE) Vivid c ced nceaccccs

Camp v. United States, 413 F.2d 419 (Sth Cir.

arch ri Cela dha 6 Ue Gk ee cob Ewa he Sees

Castaneda v. Partida, 430 U.S. 482, 97 S.Ct.

Berm. OR Ma OOO ik Sek. ex vc bsavnkcs 6,7,8,9,10

Duren v. Missouri, ___. U.S. ___, 47 Law

ME ND os oie sau odo vhs eee eK ee vgs

Hernandez v. Texas, 347 U.S. 475, 74 S.Ct.

IE ve bass cow ae bk deed obecce

United States v. Greenberg, 200 F.Supp. 382

SPE a BEE hae Gh Pe cats abd b'e boos Calves toa e

Whitus v. Georgia, 385 U.S. 545, 87S.Ct. 643,

Pe ME PP TEDIOED A ciccbichvscdccceer cocves

IN THE

SUPREME COURT OF THE UNITED STATES

OCTOBER TERM, 1978

No.

MARY FRANCIS LOPEZ,

Petitioner,

versus

UNITED STATES OF AMERICA,

Respondent.

PETITION FOR A WRIT OF CERTIORARI

TO THE UNITED STATES COURT OF APPEALS

FOR THE FIFTH CIRCUIT

The Petitioner, Mary Francis Lopez, prays that a writ

of certiorari issue to review the judgment of the Unit-

ed States Court of Appeals for the Fifth Circuit in case

number 78-5511, United States of America, Plaintiff-

Appellee, v. Mary Francis Lopez, Defendant-Appellant.

OPINIONS BELOW

The opinions and judgments of the United States

Court of Appeals for the Fifth Circuit and of the Unit-

+

years in confinement suspended, with Petitioner to be

on probation for two years with a fine of ONE THOU-

SAND AND NO/100 ($1,000.00) dollars.

It is the denial of the motion to quash the jury that

Petitioner asserts in this appeal as error by the trial

court.

In a Per Curiam opinion of January 24, 1979, a Panel of

the Court of Appeals affirmed the decision below.

Petitioner asserts that the Panel erred in affirming the

decision, as such affirmance conflicts with prior

Supreme Court decisions.

Statement of Facts

The facts show that there are a substantial number

of Spanish surnamed people in the Division of the Dis-

trict Court in which this case was tried. The U.S. Cen-

sus figures for 1970 show the percentage of Spanish

surnames amounts to 20.5% (Defendant’s Exhibit 8).

The school enrollment for the area shows the percen-

tage to be 30.9% (Defendant's Exhibit 6).

The Marshall’s Summon’s List and Jury Attendance

lists (2nd Supp. Record on Appeal) as summarized by

the attached Ratio Tables (Appendix D) reflect that

only 4.3% of those called for jury service from August,

1971, (the date the “Jury Wheel” selection plan for the

Northern District of Texas was approved by the Fifth

Circuit Judicial Council) through time of trial in 1978

had Spanish surnames.

5

REASONS FOR GRANTING THE WRIT

The Honorable Panel of the Fifth Circuit Court of

Appeals erred in affirming the conviction of Petitioner

and the denial by the District Court of Petitioner’s Mo-

tion to Quash the Jury Panel which was based on Con-

stitutional grounds that Mexican-Americans were

systematically excluded from jury service.

A citizen accused has guaranteed to him under the

Constitution the most basic right known to our sys-

tem of government: “In all criminal prosecutions, the

accused shall enjoy the right to a speedy and public trial,

by an impartial jury ...” U.S. Constitution, Sixth

Amendment (Emphasis Added). A jury drawn from a

system that excludes a class of individuals by reason of

race, especially when the accused is a member of that

class, is not such an impartial jury. Whitus v. Georgia, 385

U.S. 545, 87 S.Ct. 643, 17 L.Ed.2d 599 (1967); Alexander

v. Louisiana, 405 U.S. 625, 92 S.Ct. 1221, 31 L.Ed.2d 536

(1972).

Mexican-Americans are members of a class which

has been recognized as “identifiable” for purposes of

determining racial exclusion. Hernandez v. Texas, 347

U.S. 475, 74 S.Ct. 667, 98 L.Ed. 866.

Petitioner, a Mexican-American, moved to quash the

petit jury based upon her constitutional right to an im-

partial jury. Through statistical as well as opinion,

reputation, and other proof. she established that a

6

significant portion of the population of the Lubbock

Division, Northern District of Texas, were Mexican-

American. Census figures place the percentage at

20.5%. Testimony of witnesses placed it higher, and

demonstrated that the percentage was rising. Likewise,

Petitioner demonstrated that the percentage of those

summoned by the U.S. Marshall averaged 4.3%.

CaStaneda v. Partida, 430 U.S. 482, 97 S.Ct. 1272, 51

L.Ed.2d 498, establishes the rule to be applied in deter-

mining whether a jury selection procedure passes con-

stitutional muster where race is a factor:

“In order to show that an equal protection

violation has occurred in the context of grand

jury selection, the defendant must show that

the procedure employed resulted in substan-

tial underrepresentation of his race or of the

identifiable group to which he belongs. .. .

Once the defendant has shown substantial underrepre-

sentation of his group, he has made out a prima facie case

of discriminatory purpose, and the burden then

shifts’ to the State to rebut that case.”

(Emphasis added) Castaneda, supra 430 U.S. at

494, 495.

In the case at bar, defendant has quite clearly shown

such a substantial underrepresentation; yet the

Government has utterly failed to rebut the evidence

and the prima facie case.

7

Castenada establishes a two-prong basis for deter-

mination of the prima facie case: first, that the group is

a recognizable, distinct class; and second, that the

underrepresentation be proved over a significant

period of time, by comparison of percentages of the

class in the general population to the percentage of the

class included in the jury selection process. 430 U.S. at

494.

Castaneda establishes another element that may be

proved to support the claim of discriminatory practice:

proof of a system not racially neutral. “Finally, as not-

ed above, a selection procedure that is susceptible of

abuse or is not racially neutral supports the presumption of

discrimination raised by the statistical showing.” (Emphasis

added). Castaneda, supra, 430 U.S. at 494. Herein lies the

error of the Panel in its Per Curiam decision: it failed to

distinguish a prima facie showing and presumption of

discrimination from the shifting of the burden of proof

to the Government. The Panel says that Castaneda re-

quires a showing of intentional discrimination; yet the

case holds that the presumption of discrimination has

arisen prior to any need for a showing of intent.

The proof in Castaneda was primarily that of statistics.

The Court agreed that these statistics established a

prima facie case of discrimination. In the very next

sentence, the Court stated: “Supporting this conclusion is

the fact that the Texas system of selecting grand jurors

is highly subjective.” (Emphasis added) 430 U.S. at 487.

The conclusion of discrimination had already been

made from statistical evidence. The same conclusion

&

exists in the case at bar. Seven years of grossly dis-

proportionate percentages cannot be ignored. Yet the

Government has attempted to do so.

The Supreme Court has had occasion to write on this

subject in the context of sex discrimination in Duren v.

Missouri, U.S. ___, 47 Law Week 4089 (1979).

That case held a Missouri jury selection system which

allowed women to “opt out” of jury service was fatally

defective due to the consistently disproportionate

numbers of women on venires. Duren repeats the req-

uisite of Castaneday and yet it adds another method of

proof of discriminatory system. That proof exists in

showing a consistent, continuing exclusion of the class from |

the venires. Mr. Justice White, writing for the Court

states:

“{Duren’s] undisputed demonstration that a

large discrepancy occurred not just occasionally

but in every weekly venire for a period of nearly

a year manifestly indicates that the cause of the

underrepresentation was systematic — that is,

inherent in the particular jury-selection

process utilized ... The resulting dispropor-

tionate and consistent exclusion of women

from the jury wheel and at the venire stage was

quite obviously due to the system by which juries

were selected. Petitioner demonstrated that

the underrepresentation of women in the final

pool of prospective jurors was due to the opera-

tion of Missouri's exemption criteria —

o

9

whether the automatic exemption for women

or other statutory exemptions — as im-

plemented in Jackson County.” 47 Law Week at

4091.

Where Duren proved a disproportion weekly for one

year, Petitioner has proved such exclusion for seven

years.

The exclusion in Duren was systematic; yet the Court

did not make any requirement of intent, as would the

Panel’s decision in the instant case. On the contrary,

the low percentage of women in Duren probably came

from the ability of the women to “opt out” of the jury

pool. This shows no “intent” on the part of the state;

yet that selection procedure was declared un-

constitutional.

The Panel also cites United States v. Arlt, 567 F.2d 1295,

as somehow controlling. Notwithstanding the fact that

the true holding of the case was that no appellant is en-

titled to two appeals, and that the judgment was

“Appeal dismissed,” the dicta in the case is not relevant

to the case at bar. There, Arlt failed to prove that a

cognizable class was systematically excluded from the

jury selection process. Here, the evidence is over-

whelming that such a systematic exclusion exists.

Here, the system is the problem. The Panel is correct in

that appellant does not contend that the District Clerk

discriminated in making up the jury panels. But, as

noted in Castaneda, “sometimes a clear pattern, unex-

10

plainable on grounds other than race, emerges from

the effect of the state action even when the governing

legislation appears neutral on its face.” 430 U.S. at 493.

Even though the Mexican-American community may

and even has succeeded in electing a Mexican-

American representative to the State Legislature, who

testified at trial (Vol. 2, Tr. 28-37), such limited

successes are inapplicable to a determination of dis-

crimination under any “ruling party” theory. Castaneda,

supra.

The court in Rabinowitz v. United States, 366 F.2d 34 (Sth

Cir. 1966) incorporated by a footnote a quote from

United States v. Greenberg, 200 F.Supp. 382 (S.D.N.Y.., |

1961):

“The test is not whether voter registration lists

are used, exclusively or otherwise, as a source

of qualified jurors. The test is whether or not

the use of such lists results in an array which is

a representative cross-section of the com-

munity or from which a cognizable group or

class of qualified citizens is systematically ex-

cluded.

Further, as the court stated in Camp v. United States,

413 F.2d 419 (5th Cir. 1969):

“Use of such lists (voter registration) as the

sole source of names for jury duty is con-

stitutionally permissible unless the system

results in the systematic exclusion of a

cognizable group or class of qualified citizens.”

—~- ———— »—

11

Therefore, the dicta in Arlt is inapplicable; the system

must result in aconstitutionally fair and impartial venire

and jury.

The system here creates a substantial variance

between the proportion of the Mexican-Americans in

the general population and the proportion appearing in

the jury panels. The Government has failed entirely to

rebut the prima facie case of discrimination. The Panel

Per Curiam decision, if allowed to stand, would substan-

tially alter the rule as set forth by the Supreme Court;

that it is the Government that must provide the ac-

cused with an impartial jury made up of her peers, and

one drawn from all segments of society, including the

race in which she is included. The Government has

failed to do this; it has failed to rebut the presumption

of discrimination established by defendant's evidence.

CONCLUSION

Petitioner respectfully submits that this Court

should grant her petition for writ of certiorari and

review the decisions of the courts below, and upon

hearing reverse the decision below.

Respectfully submitted,

MARK SMITH &

ASSOCIATES

1220 Broadway, Suite 1820

Lubbock, Texas 79401

Attorney for Petitioner

12

CERTIFICATE OF SERVICE

I hereby certify that I have this day mailed three

copies of the foregoing Petition for Writ of Certiorari

to the United States Court of Appeals for the Fifth Cir-

cuit to the Honorable Wade H. McCree, Jr., Solicitor

General of the United States, Department of Justice,

Washington, D.C., 20530; and one copy to the

Honorable Roger McRoberts, Assistant United States

Attorney, C-201, U.S. Courthouse, 1205 Texas

Avenue, Lubbock, Texas 79401, by placing the same in

the United States Post Office, first class postage

prepaid, said service being made in compliance with —

United States Supreme Court Rule 33.

Mark Smith

f)

la

APPENDIX A

UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

LUBBOCK DIVISION

Docket No. CR-5-78-0008

United States of America

versus

MARY FRANCIS LOPEZ

JUDGMENT AND PROBATION/COMMITMENT

ORDER

In the presence of the attorney for the government the

defendant appeared in person on this date JULY 6,

1978.

WITH COUNSEL Mark Smith (Hired)

PLEA

X NOT GUILTY

There being a verdict of GUILTY by jury, 6/16/78.

FINDING & JUDGMENT

Defendant has been convicted as charged of the

offense(s) of Obstruction of Correspondence, in viola-

tion of Title 18, United States Code, Section 1702.

2a

SENTENCE OR PROBATION ORDER

The court asked whether defendant had anything to

say why judgment should not be pronounced. Because

no sufficient cause to the contrary was shown, or

appeared to the court, the court adjudged the defen-

dant guilty as charged and convicted and ordered that:

The ¢>fendant is hereby committed to the custody of

the Attorney General or his authorized representative

for imprisonment for a period of TWO (2) YEARS. The

execution of said sentence of imprisonment is hereby

suspended and defendant placed on probation for a

period of TWO (2) YEARS.

In addition, defendant is fined the sum of $1,000.00 to

be paid on or before August 1, 1978, and to be paid

through the U.S. Probation Office.

ADDITIONAL CONDITIONS OF PROBATION

In addition to the special conditions of probation im-

posed above, it is hereby ordered that the general con-

., ditions of probation set out on the reverse side of this

judgment be imposed. The Court may change the con-

ditions of probation, reduce or extend the period of

‘. probation, and at any time during the probation period

OK within a maximum probation period of five years

permitted by law, may issue a warrant and revoke

probation for a violation occurring during the proba-

tion period.

ls) HALBERT O. WOODWARD

HALBERT O. WOODWARD

Chief U.S. District Judge

Date July 6, 1978

3a

It is ordered that the Clerk deliver a certified copy of

this judgment and commitment to the U.S. Marshal or

other qualified officer.

APPENDIX B

UNITED STATES of America,

Plaintiff-Appellee,

versus

Mary Frances LOPEZ,

Defendant-Appellant.

No. 78-5511

Summary Calendar.*

United States Court of Appeals,

Fifth Circuit.

Jan. 24, 1979.

Appeal from the United States District Court for the

Northern District of Texas.

* Rule 18,5 Cir.; see Isbell Enterprises, Inc. v. Citizens Casualty Co. of New

York et al., 5 Cir. 1970, 431 F.2d 409, Part I.

4a

Before CLARK, RONEY and GEE, Circuit Judges.

PER CURIAM:

Mary Frances Lopez was convicted of the intentional

obstruction of correspondence in violation of 18 U.S.C.

§ 1702. During her trial, Lopez filed a motion to quash

the petit jury panel, contending that the procedures by

which jurors were selected impermissibly discriminat-

ed against Mexican-Americans. Lopez rested her

claims of discrimination squarely on constitutional

grounds; she did not contend that the procedures used

by the district court violated the Jury Section and Serv-

ice Act of 1968, 28 U.S.C. §§ 1861-1874. Lopez con-

tends that the district judge erroneously denied her

motion. We affirm.

In order to establish a prima facie case of discrim-

ination in the selection of jurors, a defendant must

show (1) that the group allegedly discriminated against

“is one that is a recognizable, distinct class singled out

for different treatment under the laws, as written or as

applied,” (2) that the group is underrepresented on jury

panels over a significant period of time, and (3) that the

selection procedure is not racially neutral or is suscepti-

ble to being used as a tool of discrimination. Castaneda v.

Partida, 430 U.S. 482, 494, 97 S.Ct. 1272, 1280, 51

L.Ed.2d 498, 510 (1977).

The district court in which Lopez was tried uses

voter registration lists to select potential jurors, as ex-

5a

pressly authorized by § 1863(b)(2). The defendant's

claim of discrimination rested entirely on statistics

showing that the percentage of Mexican-Americans

selected for jury panels was less than the percentage of

Mexican-Americans in the entire population for the

district. The district judge concluded that this under-

representation was due solely to the fact that fewer

Mexican-Americans register to vote than do other

groups within the community.

The evidence Lopez adduced to support her claim of

discrimination failed to meet the third requirement set

down in Castaneda. Lopez does not contend that the dis-

trict court clerk discriminated against Mexican-

Americans in making up the jury panels from the

voting lists, nor does she contend that Mexican-

Americans have been discriminated against in the voter

registration process. Castaneda requires that a defen-

dant show that the exclusion of a particular minority

group from jury service is due to some form of inten-

tional discrimination; “an official act is not uncon-

stitutional solely because it has a racially dispropor-

tionate impact.” Castaneda, supra, 430 U.S. at 493, 97

S.Ct. at 1279, 51 L.Ed.2d at 509; see Washington v. Davis,

426 U.S. 229, 239, 96 S.Ct. 2040, 2047, 48 L.Ed.2d 597,

607 (1976). A prima facie case of discrimination cannot

rest merely on statistics. The fact that an identifiable

minority group votes in a proportion lower than the

rest of the population and is therefore under-

represented on jury panels presents no constitutional

6a

issue. Lnited States v. Arlt, 567 F.2d 1295, 1297 (Sth Cir.

1978).

AFFIRMED.

APPENDIX C

UNITED STATES COURT OF APPEALS

FIFTH CIRCUIT

OFFICE OF THE CLERK

Edward W. Wadsworth

Clerk

February 21, 1979

TO ALL PARTIES LISTED BELOW:

NO. 78-5511 — UNITED STATES OF AMERICA v.

MARY FRANCIS LOPEZ

Dear Counsel:

This is to advise that an order has this day been entered

denying the petition for rehearing, and no member of

the panel nor Judge in regular active service on the

Court having requested that the Court be polled on

rehearing en banc (Rule 35, Federal Rules of Appellate

Procedure; Local Fifth Circuit Rule 16) the petition for

rehearing en banc has also been denied.

7a

See Rule 41, Federal Rules of Appellate Procedure for

issuance and stay of the mandate.

Very truly yours,

EDWARD W. WADSWORTH,

Clerk

Is} SALLY HAYWARD

Deputy Clerk

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