state actions that have a disparate impact upon African-Americans would violate the Equal Protection Clause; that question was not considered until almost a century later in Washington v. Davis, which reaffirmed that Strauder "established that the exclusion of [African-Americans] from grand and petit juries in criminal proceedings violated the Equal Protection Clause, but the fact that a particular jury or a series of juries does not statistically reflect the racial composition of the community does not, in itself, make out an invidious discrimination forbidden by the Clause." . See also Batson v. Kentucky References Further reading External links United States equal protection and criminal procedure case law United States jury case law United States Supreme Court cases United States Supreme Court cases of the Waite Court 1880 in United States case law African-American history of West Virginia Legal history of West Virginia 1880 in West Virginia Criminal cases in the Waite Court African-American history between emancipation and the civil rights movement Ohio County, West Virginia United States racial discrimination case law