Saturday, November 2, 2013

Duncan v. Louisiana case brief

Duncan v. Louisiana case brief summary
391 U.S. 145 (1968)

Defendant appealed a judgment of the Supreme Court of Louisiana denying his petition for a writ of certiorari to challenge his conviction for simple battery. Defendant argued that the trial court improperly denied his request for a jury trial because the Sixth and Fourteenth Amendments to the United States Constitution secured the right to jury trial in state criminal prosecutions where a sentence as long as two years could be imposed.


  • Defendant was charged with simple battery, a misdemeanor punishable by a maximum of two years imprisonment and a $ 300 fine. 
  • Defendant sought trial by jury, but because the Louisiana Constitution grants jury trials only in cases in which capital punishment or imprisonment at hard labor may be imposed, the trial court denied the request. 
  • Defendant was convicted and sentenced to serve 60 days in the parish prison and pay a fine of $ 150. 
  • After the state supreme court denied his petition for a writ of certiorari, defendant sought review in the federal court. 
  • The Court held that a crime punishable by two years in prison was a serious crime and not a petty offense. 
  • Consequently, defendant was entitled to a jury trial and the trial court erred in denying it. 
  • In so ruling, the Court opined that the right to trial by jury guaranteed defendants in criminal cases in federal courts by the U.S. Constitutional art. III and by the Sixth Amendment was also guaranteed by the Fourteenth Amendment to defendants tried in state courts.

The Court reversed defendant's simple battery conviction and remanded for further proceedings because the trial court erred in denying defendant's request for a jury trial. The Court ruled that although the offense was a misdemeanor, because it carried a maximum two-year sentence, it was a serious crime for which defendant was entitled to a jury trial.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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