Woodfox v. Cain
2013 U.S. Dist. LEXIS 26220
M.D. La.2013Background
- Woodfox indicted by a West Feliciana Parish grand jury in 1993 and later convicted in 1998; habeas petition challenging grand jury foreperson discrimination filed 2006; an evidentiary hearing occurred in 2012; Fifth Circuit remanded for consideration of foreperson selection; court conducted a structured, multi-stage burden-shifting analysis; court grants habeas relief for foreperson discrimination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prima facie case of foreperson discrimination established | Woodfox shows underrepresentation of African-Americans among forepersons (5/27) vs. population (44%). | State argues statistics rely on flawed baselines and that race-neutral criteria could explain disparities. | Woodfox established a prima facie case. |
| Appropriate baseline for assessing disparity | Baseline of 40.8% (actual seated non-forepersons) should be used. | Baseline of 36.62% (eligibility-based) should be used. | Court adopts Woodfox’s baseline of 40.8%. |
| Statistical significance of observed disparity | P-value demonstrates significant underrepresentation of African-Americans. | Dispute over one- vs two-tailed tests; argues insufficient significance. | P-value (.0126 one-tailed, .0185 two-tailed) shows statistical significance. |
| Rebuttal evidence of racially neutral criteria by State | State's evidence is insufficient and constitutes mere good-faith assertions. | Judges used race-neutral criteria (education, employment, character) to select forepersons. | State failed to rebut the prima facie case with objective, racially neutral criteria. |
| Scope of evidence and stages of burden-shifting | Woodfox may present evidence about Ramshur’s selections after rebuttal stage. | Castaneda framework limits focus to selection process over time; Ramshur evidence unnecessary if rebuttal fails. | Because rebuttal failed, Ramshur-specific evidence was immaterial. |
Key Cases Cited
- Castaneda v. Partida, 430 U.S. 482 (1977) (prima facie shows underrepresentation; burden shifts to State to rebut with neutral criteria)
- Langley, 813 So.2d 356 (La. 2002) (eligible population statistics; upright baseline explanation for discrimination analysis)
- Guice v. Fortenberry, 722 F.2d 276 (5th Cir. 1984) (affirmation of good faith insufficient to rebut discrimination)
- Johnson v. Puckett, 929 F.2d 1067 (5th Cir. 1991) (need for objective, racially neutral criteria; good faith alone insufficient)
- Alexander v. Louisiana, 405 U.S. 625 (1972) (burden shifts to show racially neutral procedures produced monochromatic result)
- Moultrie v. Martin, 690 F.2d 1078 (4th Cir. 1982) (statistical evidence examined to assess prima facie case)