Baldwin v. New York | |
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Argued Dec 9, 1969 Decided June 22, 1970 | |
Full case name | Robert Baldwin v. State of New York |
Citations | 399 U.S. 66 ( more ) 90 S. Ct. 1886; 26 L. Ed. 2d 437 |
Argument | Oral argument |
Case history | |
Prior | |
Holding | |
A defendant accused of a serious offense must be afforded the right to a trial by jury, while a petty offense does not give a defendant a right to a jury trial. | |
Court membership | |
| |
Case opinions | |
Majority | White, joined by Brennan and Marshall |
Concurrence | Black, joined by Douglas |
Dissent | Burger |
Blackmun took no part in the consideration or decision of the case. | |
Laws applied | |
Sixth Amendment to the United States Constitution |
Baldwin v. New York, 399 U.S. 66 (1970), was a decision of the U.S. Supreme Court in which the Court ruled that defendants have a Sixth Amendment right to a jury trial for offenses requiring imprisonment of more than six months. [1]
Robert Baldwin was arrested in New York City for "jostling". Under the New York City Criminal Court Act, his trial was conducted without a jury, despite his request for a jury trial. Baldwin was convicted and sentenced to one year in prison, following which he appealed the case, arguing that the Sixth Amendment to the United States Constitution granted him the right to a jury trial. [2]
In 1968, the Warren court incorporated the Sixth Amendment right to a jury trial and applied it to the states. In Duncan, the defendant had been convicted of battery, which under Louisiana law was punishable by up to two years in prison. The majority opinion, authored by Justice Byron White, noted that in 49 of the 50 states, "petty offenses" were punishable by no more than one year in jail. Therefore, a crime with a possible two-year sentence was out of step with the common law definition of "petty" thus necessitating a right to trial by jury. [3]
The majority opinion, authored by Justice Byron White, narrowed the decision of Duncan v. Louisiana by holding that a right to a jury trial is required for all crimes where the penalty exceeds six months imprisonment. The opinion explicitly disagreed with the prosecution's argument that the line should be drawn between misdemeanor and felony, and noted that every other state had reduced punishment for non-jury trials to no more than six months. [1]
A jury trial, or trial by jury, is a legal proceeding in which a jury makes a decision or findings of fact. It is distinguished from a bench trial in which a judge or panel of judges makes all decisions.
A summary offence or petty offence is a violation in some common law jurisdictions that can be proceeded against summarily, without the right to a jury trial and/or indictment.
The Sixth Amendment to the United States Constitution sets forth rights related to criminal prosecutions. It was ratified in 1791 as part of the United States Bill of Rights. The Supreme Court has applied all but one of this amendment's protections to the states through the Due Process Clause of the Fourteenth Amendment.
Duncan v. Louisiana, 391 U.S. 145 (1968), was a significant United States Supreme Court decision which incorporated the Sixth Amendment right to a jury trial and applied it to the states.
Scott v. Illinois, 440 U.S. 367 (1979), was a case heard by the Supreme Court of the United States. In Scott, the Court decided whether the Sixth and Fourteenth Amendments required Illinois to provide Scott with trial counsel. To emphasize the importance of court-appointed counsel, the Court opined, "[T]he interest protected by the right to have guilt or innocence determined by a jury... while important, is not as fundamental to the guarantee of a fair trial as is the right to counsel."
Blanton v. North Las Vegas, 489 U.S. 538 (1989), is a United States Supreme Court case clarifying the limitations of the right to trial by jury.
Apodaca v. Oregon, 406 U.S. 404 (1972), was a United States Supreme Court case in which the Court held that state juries may convict a defendant by a less-than-unanimous verdict in a felony criminal case. The four-justice plurality opinion of the court, written by Justice White, affirmed the judgment of the Oregon Court of Appeals and held that there was no constitutional right to a unanimous verdict. Although federal law requires federal juries to reach criminal verdicts unanimously, the Court held Oregon's practice did not violate the Sixth Amendment right to trial by jury and so allowed it to continue. In Johnson v. Louisiana, a case decided on the same day, the Court held that Louisiana's similar practice of allowing criminal convictions by a jury vote of 9–3 did not violate due process or equal protection under the Fourteenth Amendment.
Argersinger v. Hamlin, 407 U.S. 25 (1972), is a United States Supreme Court decision holding that the accused cannot be subjected to actual imprisonment unless provided with counsel. Gideon v. Wainwright made the right to counsel provided in the Sixth Amendment applicable to the states through the Fourteenth Amendment.
Williams v. Florida, 399 U.S. 78 (1970), is a United States Supreme Court case in which the Court held that the Fifth Amendment does not entitle a defendant in a criminal trial to refuse to provide details of his alibi witnesses to the prosecution, and that the Sixth Amendment does not require a jury to have 12 members.
Burch v. Louisiana, 441 U.S. 130 (1979), was a case decided by the United States Supreme Court that invalidated a Louisiana statute allowing a conviction upon a nonunanimous verdict from a jury of six for a petty offense. The statute allowed for conviction if only five jurors agreed, and this was held to be a violation of the Sixth Amendment.
A citizen's right to a trial by jury is a central feature of the United States Constitution. It is considered a fundamental principle of the American legal system.
Ludwig v. Massachusetts, 427 U.S. 618 (1976), was a case in which the Supreme Court of the United States held that the Massachusetts two-tier court system did not deprive Ludwig of his U.S. Const., Amend. XIV right to a jury trial and did not violate the double jeopardy clause of the U.S. Const., Amend. V.
The United States Constitution contains several provisions regarding the law of criminal procedure.
Glasser v. United States, 315 U.S. 60 (1942), was a landmark decision of the US Supreme Court on two issues of constitutional criminal procedure. Glasser was the first Supreme Court decision to hold that the Assistance of Counsel Clause of the Sixth Amendment required the reversal of a criminal defendant's conviction if his lawyer's representation of him was limited by a conflict of interest.
Pointer v. Texas, 380 U.S. 400 (1965), was a decision by the United States Supreme Court involving the application of the right of to confront accusers in state court proceedings. The Sixth Amendment in the Bill of Rights states that, in criminal prosecutions, the defendant has a right "...to be confronted with the witnesses against him; to have compulsory process for obtaining witnesses in his favor..." In this case, a person arrested in Texas for robbery was deprived of the ability to cross-examine a witness when the lower court allowed the introduction of a transcript of that witness's earlier testimony at a preliminary proceeding instead of compelling attendance by the witness at trial.
McCoy v. Louisiana, 584 U.S. 414 (2018), was a United States Supreme Court case in which the Court held the Sixth Amendment guarantees a defendant the right to decide that the objective of his defense is to maintain innocence at all costs, even when counsel believes that admitting guilt offers the defendant the best chance to avoid the death penalty.
United States v. Haymond, 588 U.S. ___ (2019), is a case in which the U.S. Supreme Court struck down the five-year mandatory minimum prison sentence for certain sex offenses committed by federal supervised releases under
as unconstitutional unless the charges are proven to a jury beyond a reasonable doubt. Justices Ginsburg, Sotomayor, and Kagan joined Gorsuch's plurality opinion, while Breyer provided the necessary fifth vote with his narrow concurrence that began by saying he agreed with much of Justice Alito's dissent, which was joined by Justices Roberts, Thomas, and Kavanaugh.Ramos v. Louisiana, 590 U.S. 83 (2020), is a U.S. Supreme Court decision in which the Court ruled that the Sixth Amendment to the U.S. Constitution requires that guilty verdicts be unanimous in criminal trials. See 590 U.S. 83 at 90 (2020) "Wherever we might look to determine what the term “trial by an impartial jury” meant at the time of the Sixth Amendment's adoption—whether it's the common law, state practices in the founding era, or opinions and treatises written soon afterward—the answer is unmistakable. A jury must reach a unanimous verdict in order to convict." Only cases in Oregon and Louisiana were affected by the ruling because every other state already had this requirement. The decision incorporated the Sixth Amendment requirement for unanimous jury criminal convictions against the states, and thereby overturned the Court's previous decision from the 1972 cases Apodaca v. Oregon and Johnson v. Louisiana.
Edwards v. Vannoy, 593 U.S. ___ (2021), was a United States Supreme Court case involving the Court's prior decision in Ramos v. Louisiana, 590 U.S. ___ (2020), which had ruled that jury verdicts in criminal trials must be unanimous under the Sixth Amendment to the U.S. Constitution. The Supreme Court ruled 6–3 that Ramos did not apply retroactively to earlier cases prior to their verdict in Ramos.
Johnson v. Louisiana, 406 U. S. 356 (1972), was a court case in the U.S. Supreme Court involving the Due Process Clause and Equal Protection Clause of the Fourteenth Amendment to the United States Constitution. The U.S. Supreme Court ruled that the Louisiana law that allowed less-than unanimous jury verdicts to convict persons charged with a felony, does not violate the Due Process clause. This case was argued on a similar basis as Apodaca v. Oregon.