DOES THE RIGHT TO A JURY TRIAL APPLY TO ALL OFFENSES?
Sometimes the black letter law passed by the legislature is unclear. The legislature can’t anticipate every possible fact scenario when they pass a law, so it lay to the courts to interpret the law and give guidance to what it means. This interpretation is called case law. When the court decides a certain meeting to the law it essentially answers a legal question. Lawyers and other courts then can rely on that ruling when they have a similar issue in their case. The following case answers the question above.
Blanton v. City of North Las Vegas, 489 U.S. 538 (1989).
This case answers the following question:
Does the Sixth Amendment’s right to a jury trial apply to all offenses?
The issue in this case is whether there is a constitutional right to a trial by jury for person charged under Nevada law with driving under the influence of alcohol (DUI). There is a category of petty crimes or offenses which is not subject to the Sixth Amendment jury trial provision.
Under Nevada law, a DUI is punishable by a minimum term of two days’ imprisonment and a maximum term of six months’ imprisonment. In addition, the defendant is required to pay a fine from $200 to $1,000, automatically loses their driver’s license for 90 days, and attend an alcohol abuse education course at his own expense. Repeat offenders can face increased penalties. In this case, Blanton and Fraley were both charged with a first-time DUI offense in different incidents. The municipal court denied both pretrial demands for a jury trial. The Eighth Judicial District Court denied Blanton’s request for a jury trial, but later granted Fraley’s. Blanton and the State in Fraley’s case appealed to the Supreme Court of Nevada. The Supreme Court of Nevada consolidated the two cases, along with others, and held that there is not a constitutional right to a trial by jury for a DUI offense because the maximum term of imprisonment is only six months and the maximum possible fine is $1,000. Blanton requested a writ of certiorari, and the Supreme Court granted certiorari to decide the issue.
There is a category of petty crimes or offenses which is not subject to the Sixth Amendment jury trial provision. In determining what constitutes a petty offense, the Court looks at whether the length of the authorized prison term or the seriousness of other punishment is enough in itself to require a jury trial. Under Baldwin, the Court did not hold that an offense carrying a maximum of six months imprisonment automatically qualified as a petty offense, but they did find that under society views, the offense would constitute a petty offense. Therefore, the DUI offenders in this case would not be given the right to a trial by jury since the maximum imprisonment time for a first-time DUI offense is six months imprisonment. Further, Congress has defined a petty offense to have a fine of more than $5,000. Since the DUI in Nevada only carries a maximum of $1,000 for a first-time offender, it is well below the $5,000 mark.
The Court found that the Nevada Legislature did not mean for DUI to be a serious offense. Just because the maximum term of imprisonment is six months, does not mean that an offender would automatically receive six months imprisonment; the offender could receive less than six months imprisonment, or no imprisonment at all. Further, it is of no importance that repeat offenders face increased penalties, because recidivist penalties imposed for DUI are commonplace, and the issue of penalties for repeat offenders is not a matter of importance in this specific case since the offenders in question are both first-time offenders.
The Supreme Court of the United States affirmed the decision of the Supreme Court of Nevada, finding that the Nevada DUI law does not guarantee an offender the right to a trial by jury.