Castaneda v. Partida
Facts
Texas used a "key man" grand jury selection system in which district judges appointed jury commissioners, who then selected prospective grand jurors from the community at large. Partida introduced census data showing that 79.1% of Hidalgo County's population was Mexican-American, while county grand jury records from 1962 to 1972 showed that only 39% of persons summoned for grand jury service were Mexican-American; during the 2 1/2 years of the judge involved in his case, the average was 45.5%. He also introduced census data showing socioeconomic disadvantages affecting Mexican-Americans, and the State offered no evidence attacking the statistics or explaining the disparity, other than testimony from the district judge about appointing commissioners and instructing them on qualifications. The jury commissioners themselves were not called, and the district judge admitted the results had not produced grand jury lists representative of the county's ethnic balance.
Issue
Whether Partida established a prima facie case of intentional discrimination against Mexican-Americans in Hidalgo County grand jury selection, and if so, whether the State rebutted that showing. More specifically, the Court considered whether the existence of a Mexican-American "governing majority" in county offices could by itself dispel the inference of purposeful discrimination.
Rule
To prove an equal protection violation in grand jury selection, a defendant must show that the procedure employed resulted in substantial underrepresentation of his race or other identifiable group. The defendant must establish that the group is a recognizable, distinct class, prove the degree of underrepresentation by comparing the group's proportion in the total population to the proportion called for grand jury service over a significant period of time, and show that the selection procedure is susceptible to abuse or is not racially neutral. Once this prima facie case is made, the burden shifts to the State to rebut the presumption of purposeful discrimination with evidence that permissible racially neutral criteria and procedures produced the result.
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If Diego Yazzie challenges his indictment on equal protection grounds, what is the strongest argument that he has established a prima facie case?