Friday, November 15, 2013

Baldwin v. New York case brief

Baldwin v. New York case brief summary
399 U.S. 66 (1970)

Appellant sought review of a ruling of the Court of Appeals of New York, which affirmed appellant's conviction for "jostling," and rejected his argument that N.Y. City Crim. Ct. Act § 40 violated his right to a jury trial under U.S. Constitutional amends. VI and XIV.

Appellant was arrested and charged with "jostling" in violation of N.Y. Penal Law § 165.25, a misdemeanor punishable by a maximum term of one year's imprisonment. He filed a pretrial motion for a jury trial, which was denied under the mandate of N.Y. City Crim. Ct. Act § 40that all trials in that court shall be without a jury. Appellant was convicted and sentenced to imprisonment for the maximum term. The state court of appeals affirmed the conviction, rejecting appellant's argument that § 40 was unconstitutional insofar as it denied him an opportunity for jury trial.


  • On appeal, the United States Supreme Court reversed the conviction, without reaching a majority as to the grounds for its decision. 
  • Noting that U.S. Constitutional amends. VI and XIV allowed "petty" offenses to be tried without a jury, three members of the Court concluded that no offense punishable by more than six month's imprisonment could be deemed "petty." 
  • Two members of the Court stated that, pursuant to the language of U.S. Constitutional Article III, § 2, cl. 3, and U.S. Constitutional amendment VI, the constitutional guarantee to a jury trial applied in all criminal prosecutions, without distinction between petty and serious offenses.

Reversing the judgment below, the Court reversed appellant's conviction, without reaching a majority as to the grounds for its decision.

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