A U.S.Court of Appeals upheld a plan to subtract the names of white prospective jurors until the proportion of racial minorities in the pool matches the proportion in the population violated the equal protection rights of white jurors in Purkett v.Elem (1995).

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In Purkett v. Elem (1995), the U.S. Supreme Court did not address a plan to adjust the racial composition of a jury pool. Instead, the case concerned the permissibility of a prosecutor's race-neutral explanation for using peremptory challenges to strike African American jurors during a criminal trial.

A USCourt of Appeals Upheld a Plan to Subtract the Names