Duncan v. Louisiana

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.

Facts. In 1966, the Appellant was driving his car when he saw his two younger black cousins on the side of the road with four white boys. The Appellant’s cousins had recently transferred to another school with reported racial problems. The Appellant stopped the car and got out to approach the six boys. A discussion ensued and the Appellant and his cousins decided to get back into the car and leave. Prior to getting into the car, a white boy testified that the Appellant slapped his elbow. The Appellant stated that he merely touched the boy on the elbow. The Appellant was charged with simple battery and requested a trial by jury. His request was denied. The trial judge concluded the elements of simple battery were proven by the state and found the Appellant guilty of the crime. The Appellant sought review in the Louisiana Supreme Court, claiming the state’s denial of trial by jury was a violation of the Constitution. The Supreme Court of Louisiana denied review.

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.

Dissent. Justice John M. Harlan (J. Harlan) and Justice Potter Stewart (J. Stewart) dissenting. There are a wide range of opinions concerning the desirability of trial by jury. Among the considerations pertaining to local conditions are the size of the criminal caseload, the difficulty in obtaining jurors and other circumstances bearing on the fairness of the trial. Each state should have the right to experiment with criminal procedure in the court system. The Supreme Court, other courts and the political process exist to correct any experiments in criminal procedure that prove fundamentally unfair to individuals.

Discussion. Trial by jury is an integral part of the criminal system. It is necessary to protect against unfounded criminal charges and against judges who are too responsive to higher authority. Trial by jury is also a safeguard against overzealous prosecutors.