The Sixth Amendment to the United States Constitution fundamentally protects the basic legal rights of the defendant by facilitating their awareness of the trial process. It states that every criminal defendant should be trialed by the jury in an impartial way and has the legally supported right to meet their accusers in court (Tracz, 2019). Additionally, this amendment ensures the defendant has the power of a lawyer on their side.
Ballew v. Georgia
Facts of the Case
In Ballew v. Georgia, the United States Supreme Court considered whether the Sixth Amendment to the Constitution guarantees a criminal defendant the right to a jury composed of 12 persons. The Court reasoned that because juries are composed of laypersons and not experts, every criminal defendant does not need a jury of 12 persons to protect their rights (Guerra et al., 2019). The Court also noted that the states are free to set their own rules regarding the composition of juries and that some states do not require juries to be composed of 12 persons.
Procedural History
The case was originally heard in the Superior Court of Fulton County, Georgia. The Appellant, Ballew, was charged and tried before a jury and found guilty on all counts. He appealed his conviction to the Supreme Court of Georgia, which affirmed the conviction. He then appealed to the United States Supreme Court, which granted certiorari.
Issue(s)
The case of Ballew v. Georgia raised important issues regarding the Sixth Amendment of the Constitution. The case concerned a defendant who was tried by a jury of six rather than the twelve required by the Constitution. The defendant argued that this violated his right to a fair trial by jury (Guerra et al., 2019). The Supreme Court agreed and ruled that the Sixth Amendment requires a jury of twelve people in all criminal trials.
Decision by the Court
In the case of Ballew v. Georgia, the Supreme Court ruled that the sixth amendment does not require a jury to be composed of a specific number of individuals. Instead, the Court held that the amendment only requires that juries be composed of a “reasonable number” of people.
Reasoning and Rule of Law Applied by the Court
In Ballew v. Georgia, the reasoning behind the U.S. Supreme Court’s holding was that a conviction by a unanimous five-person jury in a trial for a non-petty offence deprives an accused of the right to trial by jury (Guerra et al., 2019). The Court reasoned that a five-person jury is not enough to provide the accused with a fair trial and that the right to trial by jury is a fundamental right that should be respected.
Analysis and Importance of the Case
The case of Ballew v. Georgia is significant for several reasons. First, it represents the Supreme Court’s first major pronouncement on the Sixth Amendment right to counsel. Second, the Court’s decision in Ballew significantly expanded the reach of the Sixth Amendment, holding that the right to counsel attaches to criminal trials and preliminary hearings where an accused is facing the possibility of jail time. Finally, Ballew is also important for its reaffirmation of the role of judges in safeguarding an accused’s constitutional rights.
Burch v. Louisiana
Facts of the Case
Burch was tried before a six-person jury in Louisiana for possessing and exhibiting obscene motion pictures. The jury was not unanimous in its verdict but found Burch guilty. On appeal, Burch argued that his conviction violated the Due Process Clause because it was not based on a unanimous verdict (Monea, 2021). The Supreme Court rejected this argument, holding that due process does not require unanimity in jury verdicts in state criminal trials. Thus, the Court affirmed Burch’s conviction.
Procedural History
The United States Supreme Court granted certiorari and agreed to hear the case on whether Burch’s conviction violates the Due Process Clause of the Fourteenth Amendment to the United States Constitution. After oral arguments were heard, the Court stated that such a conviction did violate the Due Process Clause as it infringed on the right of the defendant to have their case decided by a jury of 12 people.
Issue(s)
The main issue in the case was whether or not the accused conviction by a nonunanimous six-person jury was legal or not. The Supreme Court ruled that such a conviction was not constitutional and that all criminal jury trials in the United States must be unanimous (Monea, 2021). This ruling has had far-reaching implications for the American criminal justice system and has helped to ensure that all defendants receive a fair trial.
Decision by the Court
In the case of Burch v. Louisiana, the court ruled in favor of the accused. The court argued that a conviction by a nonunanimous six-person jury in a state criminal trial for a non-petty offense violates the accused’s right to a jury trial under the Sixth and Fourteenth Amendments of the Constitution.
Reasoning and Rule of Law Applied by the Court
The rule of law applied in this case was that a conviction by a nonunanimous six-person jury in a state criminal trial for a non-petty offense is unconstitutional (Monea, 2021). In this case, the defendant argued that his conviction should be overturned because the jury was not unanimous. The Court agreed with the defendant and overturned his conviction.
Analysis and Importance of the Case
This case is significant because it establishes that nonunanimous juries are unconstitutional and can violate the sixth and fourteen amendments. This case is important for practitioners and scholars of criminal law, as it guides the constitutionality of nonunanimous juries.
References
Guerra, A., Luppi, B., & Parisi, F. (2019). Jury size and voting requirements for criminal convictions: Assessing the tradeoffs. SSRN Electronic Journal. Web.
Monea, N. (2021). Reforming Military Juries in the Wake of Ramos v. Louisiana. 66 Naval L. Rev. 67.
Tracz, E. T. (2019). Revisiting the Right to a Speedy Trial: Reconciling the Sixth Amendment with the Speedy Trial Act. 47 Cap. U. L. Rev. 1.