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Law School Case Brief

Blanton v. N. Las Vegas - 489 U.S. 538, 109 S. Ct. 1289 (1989)

Rule:

An offense carrying a maximum prison term of six months or less is presumed for purposes of the Sixth Amendment to be viewed as a petty offense. A defendant is entitled to a jury trial in such circumstances only if he can demonstrate that any additional statutory penalties, viewed in conjunction with the maximum authorized period of incarceration, are so severe that they clearly reflect a legislative determination that the offense in question is a serious one. 

Facts:

Under a Nevada statute, a first offense of driving under the influence of alcohol (DUI) is punishable by either: (1) imprisonment for a minimum term of 2 days and a maximum term of 6 months, or; (2) the required performance of 48 hours of community service while dressed in clothing identifying the wearer as a DUI offender. In addition to such alternative penalties, the first-time DUI offender is subject to mandatory statutory penalties consisting of a fine of between $200 and $1,000, revocation of unrestricted driving privileges for 90 days, and compelled attendance at an alcohol abuse education course at the offender's expense.

In two separate cases filed in the Municipal Court of North Las Vegas, Nevada, two individuals were charged by defendant City of North Las Vegas ("City") with first-time DUI offenses under the statute. Each accused made a pretrial demand for a jury trial, which the municipal court denied. Thereafter, one accused filed a pretrial petition, in a state district court, for a writ of mandamus challenging the municipal court's jury trial denial. The district court denied the petition, and the accused appealed to the Supreme Court of Nevada. The other accused was tried and convicted in the municipal court of DUI and appealed his conviction to the district court. Holding that a Nevada statute precluding jury trials in municipal courts was unconstitutional, the district court remanded the case for a jury trial. The City petitioned the Nevada Supreme Court for a writ of certiorari challenging the district court's decision. Both accused had no prior DUI convictions and thus faced a maximum of six months' incarceration. On consolidated review of both cases, the Nevada Supreme Court held that the U.S. Constitution's Sixth Amendment did not guarantee the right to a jury trial under the statute, since the maximum prison term thereunder was 6 months and the maximum possible fine was $1,000. The case was appealed.

Issue:

Is a right to a jury trial required for a DUI offense?

Answer:

No.

Conclusion:

The Supreme Court of the United States affirmed the judgment that the federal constitution did not guarantee a right to trial by jury on a DUI offense that carried a potential maximum prison sentence of six months. The Court initially noted that no Sixth Amendment right to trial by jury existed for petty offenses. The Court further clarified that a defendant was entitled to a jury trial whenever the crime with which he or she was charged carried a maximum period of incarceration that was greater than six months. In the present case, the Court added that an offense that carried a maximum prison term of six months or less was presumed to be a petty offense. However, the Court added that a defendant would still be entitled to a jury trial if he or she could demonstrate that other statutory penalties reflected a legislative judgment that the crime was a serious one. The Court concluded that the Nevada legislature did not prescribe additional penalties that would have supported a finding that it considered DUI to be a serious offense. The potential added penalties consisted of a 90-day license suspension, community service, and a $ 1,000 fine. Therefore, the Court concluded that defendants were not entitled to a jury trial.

 

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