The first Supreme Court decisions to reverse state criminal convictions for constitutional procedural reasons involved the exclusion of African-Americans for grand and petit juries—Strauder v. West Virginia (1880), Virginia v. Rives (1880), Neal v. Delaware (1881), Carter v. Texas (1900), Rogers v. Alabama (1904), and Norris v. Alabama (1935)—and the conviction African-American defendants for crimes involving white victims in the southern states: by a mob-dominated trial, as in Moore v. Dempsey (1923); and without counsel, as in Powell v. Alabama (1932).Michael J. Klarman, The Racial Origins of Modern Criminal Procedure, 99 48 (2000).
