Facts: Duncan was convicted of simple battery (a misdemeanor) and was sentenced to serve 60 days in the parish prison and pay a fine of $150. Duncan sought a jury trial but was denied because the Louisiana Constitution grants jury trials only in cases in which capital punishment or imprisonment at hard labor may be imposed.
Defendant’s Argument: A trial by jury is “fundamental to the American scheme of justice” and protects against arbitrary rule, which is one of the major themes in our country’s settlement.
State’s Argument: If a right to a jury trial is granted in every criminal case, the state’s resources will be exhausted. Also, it is not wise to allow “laymen” to determine the facts because they are untrained. Furthermore, if the court holds that the 14th Amendment assures a right to a jury trial, it will “cast doubt on the integrity of every trial conducted without a jury.”
Judgment: Reversed and remanded.
Court’s Reasoning: The right to a jury trial in a criminal case is fundamental and present in the 6th Amendment. The 14th Amendment should incorporate this right because it is so “fundamental to the American scheme of justice.”
Dissent: The right to a jury trial varies from state to state. The state should be allowed to govern its own citizens and if its own citizens want the right to a jury in all criminal cases, they can seek it through the political process.