The Oyez Project: Criminal Procedure Issues - Jury Trial Decisions

Apodaca v. Oregon

Is a defendant's right to a trial by jury in a criminal case in a state court (as protected by the Sixth and Fourteenth Amendments) violated if the accused is convicted by a less-than-unanimous jury?

No. In a close decision the Court found that the accused's right to a jury trial does not require that juries return unanimous decisions in order to convict. After reviewing the history and function of juries in American society, the Court held that the most important function of the jury is to provide "commonsense judgment" in evaluating the respective arguments of accused and accuser. Requiring unanimity would not necessarily contribute to this function. A distinction was drawn, however, between capital and non-capital crimes.

Atlas Roofing Co. v. Occupational Safety Comm'n

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Baldwin v. New York

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Ballew v. Georgia

Does a state criminal trial by a jury of only five persons deprive the accused of the right to a trial by jury as protected by the Sixth and Fourteenth Amendments?

Yes. The Court found that a trial by jury of less than six members violated the accused's right to a trial by jury as protected by the Sixth and Fourteenth Amendments. Justice Blackmun reasoned that small juries foster poor group deliberation. Group memory of the details of testimony, the ease with which group compromises can be made, and the desire of the group to be self-critical and reflective are all hindered as the size of the jury decreases. Blackmun also relied on statistical studies to claim that the risk of jury error increased with smaller juries.

Baxstrom v. Herold

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Beacon Theatres v. Westover

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Blanton v. North Las Vegas

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Burch v. Louisiana

Does a conviction by a nonunanimous six-member jury in a state criminal trial for a nonpetty offense violate the accused's right to a trial by jury as protected by the Sixth and Fourteenth Amendments?

The Court found that convictions by the nonunanimous six-member jury violated the Constitution. Tracing the development of the Court's considerations of this issue, Justice Rehnquist indicated that Burch's case sat at the "intersection of our decisions concerning jury size and unanimity." Rehnquist relied on the Court's holding in Ballew v. Georgia (1978) and the practices in several of the states to find against convictions by nonunanimous juries of six members. Only two of the states that used six-member juries in trials for petty offenses allowed verdicts to be less than unanimous. This "near uniform judgment of the Nation" of the inappropriateness of this jury arrangement, argued Rehnquist, provided the Court with a "useful guide" in determining constitutionally allowable jury practices.

Chaffin v. Stynchcombe

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Curtis v. Loether

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Dairy Queen v. Wood

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Duncan v. Louisiana

Was the State of Louisiana obligated to provide a trial by jury in criminal cases such as Duncan's?

Yes. In a 7-to-2 decision, the Court held that the Sixth Amendment guarantee of trial by jury in criminal cases was "fundamental to the American scheme of justice," and that the states were obligated under the Fourteenth Amendment to provide such trials. Petty crimes, defined as those punishable by no more than six months in prison and a $500 fine, were not subject to the jury trial provision.

Dyke v. Taylor Implement Co.

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Granfinanciera, S. A. v. Nordberg

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Harris v. United States

Is McMillan v. Pennsylvania, 477 U.S. 79, valid after the U.S. Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466?

Yes. In a 6-3 opinion delivered by Justice Anthony M. Kennedy, the Court held that section 924(c)(1)(A) defines a single offense, in which brandishing a firearm is a sentencing factor to be found by the judge, not an offense element to be found by the jury. Reaffirming McMillan, the Court also concluded that section 924(c)(1)(A) is constitutional because basing a 2-year increase in the defendant's minimum sentence on a judicial finding of brandishing does not evade the requirements of neither the Fifth and Sixth Amendments nor Apprendi. "Apprendi's conclusions do not undermine McMillan's. There was no comparable historical practice of submitting facts increasing the mandatory minimum to the jury, so the Apprendi rule did not extend to those facts," wrote Justice Kennedy.

Johnson v. Louisiana

Do less-than-unanimous jury verdicts in certain cases violate the Due Process and Equal Protection Clauses of the Fourteenth Amendment?

The Court held that less-than-unanimous convictions did not violate the reasonable doubt standard embodied in the Fourteenth Amendment's Due Process Clause. Justice White argued that a minority opposing conviction does not prevent the other jurors from reaching their decisions beyond a reasonable doubt. Furthermore, the presence of dissenting jurors does not indicate that the state failed to uphold this standard. Finally, allowing less-than-unanimous decisions in certain cases serves a rational state purpose, not offensive to the Constitution.

Lehman v. Nakshian

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Lewis v. United States

Does a defendant who is prosecuted in a single proceeding for multiple petty offenses have a constitutional right to a jury trial where the aggregate prison term authorized for the offenses exceeds six months? May a defendant who would otherwise have a constitutional right to a jury trial be denied that right because the presiding judge has made a pretrial commitment that the aggregate sentence imposed will not exceed six months?

No. In a 7-2 opinion delivered by Justice Sandra Day O'Connor, the Court held that no jury trial right exists where a defendant is prosecuted for multiple petty offenses. Justice O'Connor wrote for the Court that the Sixth Amendment's guarantee of the right to a jury trial does not extend to petty offenses, and its scope does not change where a defendant faces a potential aggregate prison term in excess of six months for the petty offenses charged. Because the Court ruled that no jury trial right exists where a defendant is charged with multiple petty offenses, it did not reach the second question. Justice John Paul Stevens authored a dissenting opinion, in which Justice Ruth Bader Ginsburg joined.

Lorillard v. Pons

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Ludwig v. Massachusetts

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Lytle v. Household Mfg., Inc.

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Magenau v. Aetna Freight Lines

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Markman v. Westview Instruments, Inc.

Is the interpretation of a patent's claim, the portion of the patent document that defines the scope of the patentee's rights, a matter of fact to be decided by jurors?

No. In a unanimous decision, authored by Justice David H. Souter, the Court held that the construction of a patent, including terms of art within its claim, is exclusively within the province of the court. Justice Souter wrote that "judges, not juries, are the better suited to find the acquired meaning of patent terms."

Mcdonough Power Equipment, Inc. v. Greenwood

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Meeker v. Ambassador Oil Corp.

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Monterey v. Del Monte Dunes At Monterey, Ltd.

Do plaintiffs have a right to a jury trial over land-use regulations when they allege constitutional violations under 42 USC Section 1983?

Yes. The Court held, in an opinion authored by Justice Anthony M. Kennedy, that property owners who file a Section 1983 civil rights suit seeking compensation for an alleged taking of their property can have a jury trial in some circumstances. "[T]he disputed questions were whether the government had denied a constitutional right outside the bounds of its authority, and, if so, the extent of any resulting damages." Justice Kennedy then added: "These were questions for the jury."

Muniz v. Hoffman

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Parklane Hosiery Co. v. Shore

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Pernell v. Southall Realty

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Ross v. Bernhard

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Simler v. Conner

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Teamsters v. Terry

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Tull v. United States

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United States v. Reynolds

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Williams v. Florida

Did a trial by jury of less than 12 persons violate the Sixth Amendment?

The Court held that "the 12-man [jury] requirement cannot be regarded as an indispensable component of the Sixth Amendment." The Court found that the purpose of the jury trial was "to prevent oppression by the Government," and that the performance of this role was not dependent on the particular number of people on the jury. The Court concluded that "the fact that the jury at common law was composed of precisely 12 is a historical accident, unnecessary to effect the purposes of the jury system and wholly without significance 'except to mystics.'"

Wooddell v. International Brotherhood Of Electrical Workers, Local 71

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