Facts of the Case

Ray Lewis, a mail handler for the United States Postal Service, was observed opening several pieces of mail and pocketing the contents. Subsequently, Lewis was charged with two counts of obstructing the mail, where each charge carries a maximum authorized prison sentence of six months. Lewis requested a jury trial. Denying his request, the Magistrate Judge ordered a bench trial, explaining that because she would not sentence him to more than six months' imprisonment, he was not entitled to a jury trial. The District Court affirmed. In affirming, the Court of Appeals noted that the Sixth Amendment jury trial right pertains only to those offenses for which the legislature has authorized a maximum penalty of over six months' imprisonment. The Court continued that, because each offense charged was petty in character, the fact that Lewis was facing more than six months' imprisonment in the aggregate did not entitle him to a jury trial. The court also reasoned that because the offense's characterization as petty or serious determined the right to a jury trial, a trial judge's self-imposed limitation on sentencing could not deprive a defendant of that right.

Question

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?

Conclusion

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.