The Fourteenth Amendment guarantees the right to a jury trial in all criminal cases which, were they to be tried in a federal court, would come within the Sixth Amendment's guarantee.
Defendant was charged with simple battery, a misdemeanor punishable by a maximum of two years imprisonment and a $ 300 fine. Defendant sought trial by jury, but because the Louisiana Constitution grants jury trials only in cases in which capital punishment or imprisonment at hard labor may be imposed, the trial court denied the request. Defendant was convicted and sentenced to serve 60 days in the parish prison and pay a fine of $ 150. After the state supreme court denied his petition for a writ of certiorari, defendant sought review in the federal court.
Was the State of Louisiana obligated to provide a trial by jury in this case?
The Court held that a crime punishable by two years in prison was a serious crime and not a petty offense. Consequently, defendant was entitled to a jury trial and the trial court erred in denying it. In so ruling, the Court opined that the right to trial by jury guaranteed defendants in criminal cases in federal courts by the U.S. Const. art. III and by the Sixth Amendment was also guaranteed by the Fourteenth Amendment to defendants tried in state courts.