How have courts dealt with the issue of race discrimination in juries?

People v. Bell (1989) 49 Cal.3d 502, 262 Cal.Rptr. 1, 778 P.2d 129 holds a showing of substantial and continuous underrepresentation of Blacks from a county's juries is insufficient even to put the county to the burden of explaining the underrepresentation. Instead, a defendant must now point to a constitutionally impermissible aspect of the county's jury selection procedure and show that this is the cause of the racial disproportionality. Such a specific showing is beyond the resources of most, if not all, defendants. Moreover, the holding itself assumes that the county, confronted with a showing that something in its method of selecting jurors is having the effect of excluding a cognizable group, has no duty to investigate and correct the system; it may continue to exclude minorities until someone is able to prove the exact cause of the problem.