ProfessorScott Caron
CaseCast™ – "What you need to know"
Brief Fact Summary. The Appellant, Gary Duncan (Appellant), was convicted of simple battery, a misdemeanor, in a Louisiana district court. Under Louisiana law, jury trials are not granted in misdemeanor cases. The Appellant claimed the state’s denial of trial by jury violated the United States Constitution (Constitution).
Synopsis of Rule of Law. The Fourteenth Amendment of the Constitution guarantees a right of trial by jury in all criminal cases.
Issue. Does a state law granting a jury trial only in cases where the penalty is capital punishment or imprisonment at hard labor violate the Constitution?
Held. Yes. The Constitution was violated when Appellant’s demand for jury trial was refused. Justice Byron White (J. White) delivered the opinion of the Supreme Court of the United States (Supreme Court). Trial by jury in criminal cases is fundamental to the American scheme of justice because it works to prevent governmental oppression. Right of trial by jury in serious criminal cases works as a defense against arbitrary law enforcement and qualifies for protection under the Due Process clause of the Fourteenth Amendment of the constitution. There has been debate over whether laymen can determine the facts in civil and criminal proceedings. Critics express a concern that juries are incapable of properly understanding evidence or determining issues of fact. However, juries do understand the evidence and come to sound conclusions in most cases presented to them. We are not suggesting that every criminal trial held before a judge is unfair or that a defendant may never be treated fairly
by a judge. The purpose of a right to jury trial is to reduce the possibility of judicial or prosecutorial unfairness.
They were wont to believe rather that the security of liberty in America rested primarily upon the dispersion of governmental power across a federal system.
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