The Fuller Court (1888–1910)

Criminal Justice

In what decision did the Fuller Court reverse the conviction of an African American defendant who alleged discrimination in the Texas grand jury system?

The Fuller Court unanimously ruled in Carter v. Texas (1900) that the conviction of Seth Carter, an African American male, must be set aside because the state court did not allow Carter sufficient opportunity to present evidence and because the grand jury system under which he was indicted was discriminatory because it did not allow for the inclusion of African Americans. The Court concluded that “the defendant has been denied a right duly set up and claimed by him under the Constitution and laws of the United States.” The Court reasoned that the state court could not simply ignore the allegations and must address them in some fashion.

Associate Justice Rufus Peckham wrote on behalf of the Fuller Court in its decision allowing a state criminal conviction with only eight jurors, rather than the typical twelve. Hulton Archive/Getty

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