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Vasquez v. Hillery | 474 U.S. 254, 106 S.Ct. 617, 88 L.Ed.2d 598 (1986)
Not all constitutional violations deprive a criminal defendant of a fair trial. As a result, courts generally won’t overturn a conviction unless a defendant can demonstrate that a violation resulted in prejudice. Historically, cases involving unconstitutional discrimination in grand-jury selection have been an exception to this rule, requiring automatic reversals of convictions. The Supreme Court revisited this exception and considered its continued relevance in Vasquez versus Hillery.
In nineteen sixty two, a grand jury indicted Booker Hillery, a Black man, for the murder of a child. Hillery moved to quash the indictment, arguing that Black potential jurors were systematically excluded from the grand jury, violating the Fourteenth Amendment’s Equal Protection Clause. The trial court denied the motion, and Hillery was convicted of first-degree murder.
After sixteen years of unsuccessful attempts to appeal his conviction, Hillery exhausted his state-court remedies. He subsequently filed a petition for a federal writ of habeas corpus against Daniel Vasquez, San Quentin Prison’s warden. The district court granted the writ, holding that Hillery had demonstrated discrimination in the grand jury. The Ninth Circuit affirmed on appeal, and the Supreme Court granted cert.
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