Duncan v. Louisiana
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Syllabus
The syllabus is prepared by the Reporter of Decisions and is not part of the opinion of the Court. It is shown as printed in the United States Reports, read from the text layer of the Library of Congress scan (optical character recognition in older volumes, not yet checked word by word against the page).
Under Louisiana law simple battery is a misdemeanor punishable by a maximum of two years' imprisonment and a $300 fine. Appellant was convicted of simple battery and sentenced to 60 days in prison and a fine of $150. He had requested a jury trial which was denied because the Louisiana Constitution grants jury trials only in cases where capital punishment or imprisonment at hard labor may be imposed. The Louisiana Supreme Court denied certiorari. Held:
Printed on p. 145 of the United States Reports, read from the text layer of the Library of Congress scan. View the page image
1. Since trial by jury in criminal cases is fundamental to the American scheme of justice, the Fourteenth Amendment guarantees a right of jury trial in all criminal cases which, were they tried in a federal court, would come within the Sixth Amendment's guarantee of trial by jury. Pp. 147-158.
Printed on p. 145 of the United States Reports, read from the text layer of the Library of Congress scan. View the page image
2. The penalty authorized for a particular crime is of major relevance in determining whether it is a serious one subject to the mandates of the Sixth Amendment, and it is sufficient here, without defining the boundary between petty offenses and serious crimes, to hold that a crime punishable by two years in prison is a serious crime and that appellant was entitled to a jury trial. Pp. 159-162.
Printed on p. 145 of the United States Reports, read from the text layer of the Library of Congress scan. View the page image
250 La. 253, 195 So. 2d 142, reversed and remanded.
Printed on p. 145 of the United States Reports, read from the text layer of the Library of Congress scan. View the page image
Provisions
The Constitution Annotated's essays on these provisions cite this case.
- Amendment XIV, Section 1suggested link
Source: Constitution of the United States of America: Analysis and Interpretation (2022 ed.), essays Amdt14.S1.4.3, Amdt14.S1.5.4.7, Amdt14.S1.5.5.2, pp. 2077, 2078, 2104, 2111.
- Amendment VIsuggested link
Source: Constitution of the United States of America: Analysis and Interpretation (2022 ed.), essays Amdt6.3.4, Amdt6.4, Amdt6.4.1, Amdt6.4.2, Amdt6.4.3, Amdt6.4.3.1, Amdt6.4.3.2, Amdt6.4.3.3, Amdt6.4.4.4, Amdt6.4.5.1, pp. 1824, 1825, 1826, 1827, 1829, 1845, 1847.
Overrules
- Maxwell v. Dow (1900)suggested link
Source: Constitution of the United States of America: Analysis and Interpretation (2022 ed.), Table of Supreme Court Decisions Overruled by Subsequent Decisions, p. 2444: Duncan v. Louisiana, 391 U.S. 145 (1968) — Maxwell v. Dow, 176 U.S. 581 (1900).
Why it is here
The library's first set of cases is chosen by fixed rules from the Constitution Annotated (2022), which cites this case as “Duncan v. Louisiana, 391 U.S. 145 (1968)”:
- most cited in essay topic Amdt6.4 (7 pages)
- cited on 14 pages