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 prospective jury.
    • 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 Edmonson.
    • 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 civil matter.
    • That’s known as the Entanglement Exception to the State Action Doctrine.