Vernellia R. Randall, When Reasonableness Is White: Black Fear, White Juries, and American Justice, Racism.org (June 13, 2026), https://www.racism.org.
The recent conviction of Karmelo Anthony, a Black teenager who claimed self-defense in the fatal stabbing of a white teenager, has generated intense debate. Some people have focused on the evidence. Others have focused on the verdict. Many have argued about whether Anthony's fear was reasonable.
I found myself thinking about a different question.
Who gets to decide what fear is reasonable?
That question goes to the heart of one of the deepest flaws in American law. The legal system often asks juries to determine whether a person's fear was reasonable. Yet when race shapes how people experience danger, can a supposedly race-neutral standard ever be truly fair?
The law speaks of the "reasonable person" as though such a person exists independent of race, history, culture, and lived experience. Judges instruct juries to determine what a reasonable person would have believed, feared, or done under the circumstances. The standard sounds objective. Fair, even.
It is neither.
The reasonable person does not exist in a vacuum. Every juror brings a lifetime of experiences, assumptions, fears, and biases into the jury room. When jurors decide whether a defendant's fear was reasonable, they are not applying a universal standard. They are applying their understanding of what fear should look like and what dangers are real.
That becomes especially problematic when the defendant is Black.
As a Black mother raising two Black sons, I taught them lessons that many white parents never have to teach their children. My sons are now 55 and 49 years old. They grew into good men, successful men, men of integrity. But when they were teenagers, they were also large boys.
I remember telling them that they had to be careful. If they got into a fight with a white child, even one their own age, people would often see only a large Black boy and a white child. Because they were bigger than many of their peers, people might assume they were the aggressor regardless of what actually happened.
Recently, one of my sons reminded me of those conversations. He remembered them clearly. He told me those lessons influenced many decisions he made growing up and helped him avoid confrontations.
I was glad those lessons may have protected him.
At the same time, I felt sadness.
No parent should have to teach a child that innocence may not be presumed. No parent should have to teach a child that other people may see danger when they look at him, even when he has done nothing wrong.
Yet Black parents have been teaching these lessons for generations.
The lessons I taught my sons did not begin with me. They were passed down through generations of Black parents who understood that survival often depended on anticipating how white people might perceive their children.
Those lessons are not based on imagination. They are based on experience.
For more than four centuries, Descendants of Africans Enslaved in the United States (DAEUS) have lived with the knowledge that they are often perceived differently and treated differently. From slavery to Jim Crow to the present day, Black Americans have learned that ordinary behavior can be interpreted as threatening. Actions viewed as harmless when committed by white people may be viewed as suspicious or dangerous when committed by Black people. Fear can be projected onto us regardless of our conduct. Assumptions about Black criminality remain deeply embedded in American institutions and culture.
That reality shapes how Black people move through the world.
It shapes what dangers we perceive.
It shapes how we respond when we believe we are threatened.
And it shapes what we reasonably fear, how we assess danger, and how quickly we understand that a situation may become life-threatening.
The Anthony case brought these questions into sharp focus. Reports indicated that no Black jurors served on the jury that ultimately convicted him.
That fact raises a fundamental question about the ability of the legal system to fairly evaluate the reasonableness of Black fear when Black experiences are absent from the jury room.
When jurors are asked to evaluate the reasonableness of a Black teenager's fear, what perspectives may be missing when no one in the jury room shares the lived experiences that often shape how Black Americans understand danger?
The problem is not simply individual prejudice. The problem is that American institutions continue to treat white experiences as universal experiences and Black experiences as deviations from the norm.
An all-white jury may faithfully follow every instruction given by the court. Yet if no member of that jury has ever lived with the realities that shape Black experiences, the jury may be missing critical information needed to evaluate reasonableness fairly.
This is one reason jury diversity matters.
Not because Black jurors automatically side with Black defendants.
Not because white jurors are incapable of fairness.
But because diverse juries bring diverse experiences into deliberations. They challenge assumptions. They expose blind spots. They broaden the collective understanding of what is reasonable under particular circumstances.
No one would suggest that a jury composed entirely of men is best positioned to evaluate the experiences of women in every circumstance. Likewise, a jury composed entirely of people who have never lived the realities of being Black may lack critical perspectives when evaluating Black fear, danger, and reasonableness.
The legal system has recognized similar problems before. Courts eventually came to understand that jurors often lacked the experiences necessary to evaluate the perceptions of battered women who defended themselves against abusive partners. The law gradually acknowledged that experiences unfamiliar to many jurors could shape perceptions of danger.
Yet courts remain reluctant to acknowledge the role race plays in shaping fear.
The concern, of course, is that recognizing race might create different standards of justice for different groups.
But ignoring race creates its own injustice.
Pretending that race does not matter does not make the legal system neutral. It simply allows the experiences of the dominant group to masquerade as universal experiences.
A legal standard that depends on human judgment cannot be separated from human experience.
That is the fundamental problem with the race-neutral reasonable person.
The standard claims universality while often reflecting the experiences of those who historically held power. It claims objectivity while excluding perspectives that may be essential to understanding the facts. It claims fairness while operating within a society where race continues to shape daily life.
The question is not whether Black defendants should receive special treatment.
The question is whether justice is possible when the experiences that shape Black perceptions of danger are treated as irrelevant to determining what is reasonable.
Whether one agrees or disagrees with the verdict in the Karmelo Anthony case is not the point of this essay. Long after the headlines fade, the larger issue will remain.
For generations, Black Americans have been required to understand how white Americans see them in order to survive.
It is time for the legal system to require juries to understand how Black Americans experience the world before deciding what fears are reasonable.
That cannot happen when Black perspectives are entirely absent from the jury room.
If lived experience matters, then representation matters.
The legal system should ensure meaningful racial representation on juries, particularly in cases involving cross-racial violence, self-defense claims, police encounters, hate crimes, and other disputes in which perceptions of danger, threat, credibility, and fear are central issues. The same concerns may arise in civil cases where jurors are asked to evaluate injuries, damages, intent, or reasonableness across racial lines.
Courts should eliminate peremptory challenges and permit only challenges for cause. For generations, peremptory challenges have been one of the primary tools used to reduce racial diversity on juries while maintaining the appearance of neutrality.
Judges should provide jurors with meaningful instructions regarding both explicit and implicit racial bias. Jurors should be instructed to ask themselves whether they would evaluate the evidence differently if the races of the parties were reversed. If the answer is yes, they should confront why.
Most importantly, the legal system must abandon the fiction that a race-neutral reasonable person exists independent of history and lived experience. The reasonable person has always been shaped by social realities. The question is whose realities count.
Until Black experiences are given equal weight in determining what fears are reasonable, equal justice will remain elusive. A legal system that evaluates Black fear through overwhelmingly white perspectives cannot honestly claim to be race-neutral.
When reasonableness is defined without Black experiences, reasonableness becomes white.
Vernellia R. Randall, Professor Emerita of Law, University of Dayton School of Law. This article was drafted with the assistance of ChatGPT, an AI language model.

