State of Iowa v. Kelvin Plain Sr.

HECHT, Justice.

An all-white jury in Black Hawk County convicted the defendant, a black man, of one count of harassment in the first degree, an aggravated misdemeanor under Iowa Code section 708.7(1)(6) (2015). On appeal, the defendant raises several claims of error, including that the district court erred in using only the absolute disparity method for assessing the representativeness of a jury pool when considering whether the racial composition of the jury pool violated the defendant’s Sixth Amendment right to an impartial jury. We abandon the exclusive use of absolute disparity as a test…