Each of these Sixth Amendment Court Cases is somehow significant to the way
the Supreme Court has interpreted the Right to Trial by Jury Clause in
the Sixth Amendment to the US Constitution. Well, most are significant, some are just interesting! You can read about the history and meaning of the Sixth Amendment here.
Sixth Amendment Court Cases - Right to Trial by Jury Clause cases -
Williams vs. Florida
In a case called Williams vs. Florida, 1970, the Supreme Court
changed its previously held position, a position held for over 150
years, that a jury did not have to be made up of twelve people. This
was a case about a thief who had been tried by a six person Florida
jury. The thief claimed his right to trial by jury had been violated
because the jury did not consist of twelve members.
The Court disagreed. The Court recognized that a jury had always had twelve people, but said neither the 6th Amendment Right to Trial by Jury Clause, nor any other mentions of trial by jury in the Constitution or in the writings of the Founding Fathers, said anything about the necessary size of the jury. Instead, the Court said the Founding Fathers intent was on the purpose of the jury, not the size. About the size of the jury, the Court stated that:
"...the number should probably be large enough to promote group deliberation, free from outside attempts at intimidation, and to provide a fair possibility for obtaining a representative cross-section of the community. But we find little reason to think that these goals are in any meaningful sense less likely to be achieved when the jury numbers six than when it numbers 12 -- particularly if the requirement of unanimity is retained. And, certainly the reliability of the jury as a fact finder hardly seems likely to be a function of its size."
The court did not set a lower size limit on a jury in this case. It
just established that a jury did not have to have twelve people to
satisfy the Right to Trial by Jury Clause.
Sixth Amendment Court Cases - Right to Trial by Jury Clause cases -
Ballew vs. Georgia
In Ballew vs. Georgia, 1978, the Court did set a lower limit on the size of juries. The Court concluded that a five person jury would not satisfy the Right to Trial by Jury Clause because with such a small jury it would be harder to fulfill the requirements listed in Williams vs. Florida such as promoting group deliberation, preventing outside intimidation and accurately representing a cross-section of the community.
Sixth Amendment Court Cases - Right
to Trial by Jury Clause cases -
Taylor vs. Louisiana
In Taylor vs. Louisiana,
1975, the Court made a judgment about the makeup of juries. Louisiana
had a provision that allowed men to serve on juries freely, but women
could serve on juries only if they had notified the government that
they were interested in serving on a jury. This caused most juries to
consist of men only.
In 1975, the defendant was convicted by an all male jury and claimed that his 6th Amendment right to trial by jury had been violated because the jury did not adequately represent a cross-section of the local community.
Justice Byron White wrote in the Court's decision:
requirement that a petit jury be selected
from a representative cross-section of the community, which is
fundamental to the jury trial guaranteed by the Sixth Amendment, is
violated by the systematic exclusion of women from jury panels, which
in the judicial district here involved amounted to 53% of the citizens
eligible for jury service."
Consequently, the Court threw out the guilty verdict. By the way, a petit jury refers to any trial jury, as opposed to a grand jury, which does not try cases, but delivers indictments. Petit, of course, means small. So, petit jury - grand jury. Get it? You can read more about grand juries on the Grand Jury Clause page here.
Sixth Amendment Court Cases - Right to
Trial by Jury Clause cases -
Blakely vs. Washington
The Supreme Court's decision in a 2004 case called Blakely vs. Washington
sent shockwaves throughout the state and federal judicial systems. In this
case a man was given a 90 year sentence for kidnapping his estranged
wife. This sentence fit within the federal government's sentencing
guidelines. However, the facts, as determined by the jury, only called
for a maximum sentence of 53 years.
The defendant claimed that his 6th Amendment right to have a jury determine the facts of which he was guilty had been violated. The Court agreed. Justice Antonin Scalia made this statement in the Court's opinion, referring to an earlier case in the state of Washington:
"When a judge imposes an
exceptional sentence, he must set forth
findings of fact and conclusions of law supporting it. A
reviewing court will reverse the sentence if it finds that "under a
clearly erroneous standard there is insufficient evidence in the record
to support the reasons for imposing an exceptional sentence."
Consequently, the Court threw out the lengthy sentence. The Blakely case threw the
judiciary into confusion because many, many sentences were determined
in the same way the judge in this case determined the sentence. Some
people thought the entire federal sentencing guidelines would have to
be redrawn and many people already sentenced and serving time would
have to be resentenced. Justice Scalia made clear in his ruling that
the jury must determine the facts of which the criminal is accused. He
also said that this did not eliminate the judge's ability to increase
the length of the sentence, as long as there were specific facts to
justify the length, and as long as the sentence did not go past the
maximum federal guidelines.
Read more about the history and meaning of the Right to Trial by Jury Clause here.
more about the history and meaning of the 6th Amendment here.
Learn more about Sixth Amendment Court Cases relating to the following Sixth Amendment clauses:
Sixth Amendment Court Cases - Speedy Trial Clause
Sixth Amendment Court Cases - Public Trial Clause
Sixth Amendment Court Cases - Arraignment Clause
Sixth Amendment Court Cases - Confrontation Clause
Sixth Amendment Court Cases - Compulsory Process Clause
Sixth Amendment Court Cases - Right to Counsel Clause
If you would like to read about the meanings of each amendment, go to
Ten Amendments page here.
to the Bill of Rights
Learn about the 1st Amendment here.
Learn about the 2nd Amendment here.
Learn about the 3rd Amendment here.
Learn about the 4th Amendment here.
Learn about the 5th Amendment here.
Learn about the 6th Amendment here.
Learn about the 7th Amendment here.
Learn about the 8th Amendment here.
Learn about the 9th Amendment here.
Learn about the 10th Amendment here.
Read the Bill of Rights here.
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