Michigan v. Bryant (Opinion)
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This case presented the question of whether Defendant Ramon Bryant was denied his Sixth Amendment right to an impartial jury drawn from a fair cross section of the community. A fair-cross-section claim under the Sixth Amendment requires a defendant to make a prima facie case as set forth by the United States Supreme Court in "Duren v Missouri," (439 U.S. 357 (1979)). The Court of Appeals concluded that defendant had satisfied the three Duren prongs, establishing a violation of his right to an impartial jury drawn from a fair cross section of the community, and granted defendant a new trial. In its review, the Michigan Supreme Court concluded that the Court of Appeals erred because defendant failed to show under the second prong that the representation of African-Americans in venires from which juries were selected was not fair and reasonable in relation to the number of African-Americans in the community. The Court held "that when applying all the relevant tests for evaluating the representation data, a court must examine the composition of jury pools or venires over time using the most reliable data available to determine whether representation of a distinct group is fair and reasonable. Having considered the results of these tests using the most reliable data set, which included the composition of jury pools or venires over a three-month period, [the Court concluded] that defendant failed to show that the representation of African-Americans was not fair and reasonable."
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