Baldwin v. New York explained

Litigants:Baldwin v. New York
Arguedate:Dec 9
Argueyear:1969
Decidedate:June 22
Decideyear:1970
Fullname:Robert Baldwin v. State of New York
Usvol:399
Uspage:66
Parallelcitations:90 S. Ct. 1886; 26 L. Ed. 2d 437
Oralargument:https://www.oyez.org/cases/1969/188
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,
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.
Majority:White
Joinmajority:Brennan and Marshall
Concurrence:Black
Joinconcurrence:Douglas
Dissent:Burger
Notparticipating:Blackmun
Lawsapplied:Sixth Amendment to the United States Constitution

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.

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.

Duncan v. Louisiana

See 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.[1]

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.

Notes and References

  1. .