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141741 - People v Bryant (Ramon)

The People of the State of Michigan,
Timothy K. McMorrow
(Appeal from Ct of Appeals)
(Kent – Kolenda, D.)
Ramon Lee Bryant,
Arthur James Rubiner


​ A computer error in Kent County resulted in a disproportionately low number of juror questionnaires being sent to residents of the zip codes that contained the county’s highest concentrations of racial minorities. The defendant, who was convicted of several crimes following a jury trial, objected that African-Americans were underrepresented in the jury pool. After an evidentiary hearing, the trial court denied the defendant’s motion for a new trial. The Court of Appeals reversed, ruling that the defendant’s Sixth Amendment right to a jury drawn from a fair cross-section of the community had been violated. In evaluating whether a distinctive group has been sufficiently underrepresented so as to violate the Sixth Amendment’s fair cross-section requirement, may a court examine only the composition of the defendant’s particular jury venire, or must a court examine the composition of broader pools or arrays of prospective jurors? Must a defendant’s claim of underrepresentation be supported by hard data, or are statistical estimates permissible? If so, under what circumstances? Was any underrepresentation of African-Americans in the defendant’s venire, or in Kent County jury pools, the result of systematic exclusion of African-Americans?