# Petition — Lopez v. United States

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Petition
- **Published:** January 1, 1979
- **Citation:** 442 U.S. 947

## Text

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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CRF ee WIERD ois i ccc cccecceecccccess 2
CONSTITUTIONAL PROVISIONS _#IN-
RG IN ae 2
yey os wy eee 3
Course of Proceedings and Disposition in
Re ee eek s Saw Kalan b'a.i)4.00-0:0'0 4's 3
i iid oe caine v0ccrecenss 4
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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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385005_2664%3A1. Public record. Not legal advice.