Lewis v. United States case brief summary
518 U.S. 322 (1996)
CASE FACTS
The criminal argued that where a defendant was charged with multiple petty offenses in a single prosecution, the Sixth Amendment required that the aggregate potential penalty was the basis for determining whether a jury trial was required. He contended that the Court must look to the aggregate prison term to determine the existence of the jury trial right, not to the petty character of the offenses charged.
DISCUSSION
CONCLUSION
The Court affirmed the judgment of the court of appeals holding that the criminal was not entitled to a jury trial. The Court held that no jury trial right existed where a defendant was prosecuted for multiple petty offenses. The Sixth Amendment'sguarantee of the right to a jury trial did not extend to petty offenses, and its scope did not change when petty offenses were aggregated in a single proceeding.
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518 U.S. 322 (1996)
CASE SYNOPSIS
Petitioner criminal was charged with
two counts of obstructing the mail, 18 U.S.C.S. § 1701. Each
count carried a maximum authorized prison sentence of six months. The
magistrate judge granted respondent government's motion for a bench
trial. The criminal sought review of the denial of a jury trial. The
district court affirmed. The Court of Appeals for the Second Circuit
affirmed. The criminal appealed.CASE FACTS
The criminal argued that where a defendant was charged with multiple petty offenses in a single prosecution, the Sixth Amendment required that the aggregate potential penalty was the basis for determining whether a jury trial was required. He contended that the Court must look to the aggregate prison term to determine the existence of the jury trial right, not to the petty character of the offenses charged.
DISCUSSION
- The Court disagreed.
- The Court held that no jury trial right existed where a defendant was prosecuted for multiple petty offenses.
- The Sixth Amendment's guarantee of the right to a jury trial did not extend to petty offenses, and its scope did not change where a defendant faced a potential aggregate prison term in excess of six months for petty offenses charged.
- To determine whether an offense was serious for Sixth Amendment purposes, the Court looked to the legislature's judgment, as evidenced by the maximum penalty authorized.
- Where the offenses charged were petty, and the deprivation of liberty exceeded six months only as a result of the aggregation of charges, the jury trial right did not apply.
CONCLUSION
The Court affirmed the judgment of the court of appeals holding that the criminal was not entitled to a jury trial. The Court held that no jury trial right existed where a defendant was prosecuted for multiple petty offenses. The Sixth Amendment'sguarantee of the right to a jury trial did not extend to petty offenses, and its scope did not change when petty offenses were aggregated in a single proceeding.
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