Edmondson v. Leesville Concrete Co.
500 U.S. 614 (1991)
Edmonson was working on a
Federal military base and got run over by a cement truck owned by
Leesville. He sued for negligence.
Edmonson requested a trial by
jury. During the jury selection (aka the voir dire), Leesville removed all black people from the
They used their preemptory
challenges, which allow a litigant to
reject a number of jurors without giving a reason.
Citing Batson v. Kentucky (476 U.S. 79 (1986)), Edmonson argued that
Leesville couldn't racially discriminate against potential jurors.
Leesville argued that the Batson decision was based on the Equal Protection
Clause of the 14th Amendment, which only applies for governmental actions
(aka the State Action Doctrine). Therefore it is
inapplicable in a civil proceeding.
The US Supreme Court found for
The US Supreme Court found
that although use of a State-sanctions, private remedies, or procedures
does not rise, by itself, to the level of State action, there is State
action when private parties make extensive use of State procedures with
"the overt, significant assistance of State officials."
Basically, this case said that
because the government is too intimately involved in civil litigation,
litigants are bound to constitutional protections, even though it is a
That's known as the Entanglement
Exception to the State