Duncan v. Louisiana

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Following is the case brief for Duncan v. Louisiana, United States Supreme Court, (1968)

Case summary for Duncan v. Louisiana:

  • Duncan was charged with simple battery and requested a jury trial.
  • The court denied his request as the state only permitted jury trials for capital offenses and Duncan was found guilty.
  • Duncan appealed his conviction, claiming the denial of his request for a jury trial violated his Sixth Amendment right.
  • The Court held that the right to a jury trial in criminal cases is fundamental to the American scheme of justice since it works to prevent governmental oppression by overzealous prosecutors and judges who are overly responsive to higher authority.

Duncan v. Louisiana Case Brief

Statement of the facts:

Duncan was charged with simple battery and requested a trial by jury. Duncan’s request was denied since the state constitution only permitted jury trials when capital punishment could be imposed. After a bench trial, Duncan was convicted of simple battery in state court. In Louisiana, battery is a misdemeanor carrying a maximum sentence of a $300 fine and two years in prison. Duncan was required to pay a $150 fine and sentenced to sixty days in prison.

Procedural History:

Duncan appealed his conviction claiming his Constitutional right have a jury trial had been violated. The state supreme court denied certiorari and Duncan appealed to the United States Supreme Court.

Rule of Law or Legal Principle Applied:

Under the 14th Amendment, an individual has a right to a jury trial in state proceedings when they would have otherwise been entitled to a jury trial in federal court under the Sixth Amendment.

Issue and Holding:

Does the Sixth Amendment right to a trial by jury apply to state proceedings through the Fourteenth Amendment? Yes.

Judgment:

The Court reversed the lower court’s decision.

Reasoning:

The Court held that many of the Amendments to the Constitution have been held as applicable to the states through the 14th Amendment.

The test previously set forth for holding an amendment as applicable to the states is whether the protected right is of “fundamental principles of liberty and justice which lie at the base of all our civil and political institutions.”

Having a right to a jury trial is imperative for criminal defendants to prevent domination by the government. The right also provide “safeguards against overzealous prosecutors or compliant, biased, or eccentric judges.”

The nation, has demonstrated a deep regard for the right of a jury trial. As a result, the Court held that this right rises to the standard of a fundamental principle of liberty and justice and should be protected and respected by the Due Process Clause and the states.

Concurring or Dissenting opinion:

Concurring (Black):

The 14th Amendment, incorporates the Bill of Rights to the states. In addition, the Privileges and Immunities Clause can also be used to grant jury trials in state courts

Concurring (Fortas):

The right to a jury trial is absolute for serious offenses, however, states should be free to develop their own rules regarding jury trial procedures absent weight from historical or federal standards.

Dissenting (Harlan and Stewart):

The Constitution’s Due Process Clause requires criminal proceedings to be “fundamentally fair” in all respects. Regardless, the requirement of fundamental fairness does not equate to uniform rules among the state and federal courts. Uniformity of procedure by courts should only be required when necessary for promoting basic fairness, and the right to a trial by jury should not be included in that category.

Significance:

Duncan v. Louisiana set the precedent that all states must permit a criminal defendant the right to have a trial by jury. In addition,this right stems from the Sixth Amendment and is applicable to the states through the 14th Amendment.

Student Resources:

https://supreme.justia.com/cases/federal/us/391/145/case.html
https://www.law.cornell.edu/supremecourt/text/391/145
http://www.casebriefs.com/blog/law/criminal-law/criminal-law-keyed-to-kadish/how-guilt-is-established/duncan-v-louisiana-6/2/