Baldwin v. New York

Baldwin v. New York, 399 U.S. 66 (1970), was a decision of the U.S. Supreme Court in which the Court ruled that defendants have a Sixth Amendment right to a jury trial for offenses requiring imprisonment of more than six months.[1]

Baldwin v. New York
Argued Dec 9, 1969
Decided June 22, 1970
Full case nameRobert Baldwin v. State of New York
Citations399 U.S. 66 (more)
90 S. Ct. 1886; 26 L. Ed. 2d 437
ArgumentOral argument
Case history
Prior
  • Hogan v. Rosenberg, 58 Misc. 2d 585, 296 N.Y.S.2d 584 (Sup. Ct. 1968)
  • Affirmed in part, reversed in part, 24 N.Y.2d 207, 247 N.E.2d 260 (1969)
  • Reargument denied sub. nom., People v. Baldwin, 27 N.Y.2d 737, 262 N.E.2d 683 (1970)
  • Probable jurisdiction noted, Baldwin v. New York, 395 U.S. 932 (1969)
Holding
A defendant accused of a serious offense must be afforded the right to a trial by jury, while a petty offense does not give a defendant a right to a jury trial.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
Hugo Black · William O. Douglas
John M. Harlan II · William J. Brennan Jr.
Potter Stewart · Byron White
Thurgood Marshall · Harry Blackmun
Case opinions
MajorityWhite, joined by Brannan and Marshall
ConcurrenceBlack, joined by Douglas
DissentBurger
Blackmun took no part in the consideration or decision of the case.
Laws applied
Sixth Amendment to the United States Constitution

Background

Robert Baldwin was arrested in New York City for "jostling". Under the New York City Criminal Court Act, his trial was conducted without a jury, despite his request for a jury trial. Baldwin was convicted and sentenced to one year in prison, following which he appealed the case, arguing that the Sixth Amendment to the United States Constitution granted him the right to a jury trial.[2]

Duncan v. Louisiana
Main article: Duncan v. Louisiana

In 1968, the Warren court incorporated the Sixth Amendment right to a jury trial and applied it to the states. In Duncan, the defendant had been convicted of battery, which under Louisiana law was punishable by up to two years in prison. The majority opinion, authored by Justice Byron White, noted that in 49 of the 50 states, "petty offenses" were punishable by no more than one year in jail. Therefore, a crime with a possible two-year sentence was out of step with the common law definition of "petty" thus necessitating a right to trial by jury.[3]

Decision

The majority opinion, authored by Justice Byron White, narrowed the decision of Duncan v. Louisiana by holding that a right to a jury trial is required for all crimes where the penalty exceeds six months imprisonment. The opinion explicitly disagreed with the prosecution's argument that the line should be drawn between misdemeanor and felony, and noted that every other state had reduced punishment for non-jury trials to no more than six months.[1]

References
  1. Baldwin v. New York, 399 U.S. 66 (1970).
  2. "Baldwin v. New York". Case Briefs. Retrieved 18 June 2020.
  3. Duncan v. Louisiana, 391 U.S. 145 (1968).
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