## Facts

- Robert Baldwin was arrested in New York City and charged with “jostling,” a Class A misdemeanor punishable by up to one year’s imprisonment.
- A New York statute governing the New York City Criminal Court required that all trials in that court proceed without a jury.
- Baldwin moved before trial for a jury trial; the motion was denied under the statute.
- Baldwin was tried without a jury, convicted, and sentenced to the maximum term of one year.
- Baldwin argued that denying a jury trial for an offense carrying a one-year potential sentence violated the Sixth Amendment jury-trial right as applied to the states through the Fourteenth Amendment.

## Issues

1. Whether the Sixth Amendment, as applied to the states, requires a jury trial for an offense carrying a maximum authorized sentence of more than six months’ imprisonment.
2. Whether a state may classify an offense punishable by up to one year in jail as “petty” and try it without a jury based on statutory labeling or local court procedure.

## Decision

- The Supreme Court reversed the state court judgment upholding Baldwin’s conviction.
- The Court held that Baldwin was constitutionally entitled to a jury trial because the charged offense authorized imprisonment for up to one year.
- The Court concluded that an offense cannot be treated as “petty” for jury-trial purposes when the authorized maximum term of imprisonment exceeds six months.
- A concurring opinion would have applied the jury-trial guarantee to all crimes.
- A dissent would have permitted New York’s non-jury procedure for the charged offense.

## Legal Principles

- The Sixth Amendment jury-trial right applies to the states through the Fourteenth Amendment for “serious” offenses.
- For determining whether an offense is “serious” or “petty,” the most important objective indicator is the maximum authorized penalty, especially the maximum term of imprisonment.
- No offense may be deemed “petty” for Sixth Amendment jury-trial purposes if imprisonment for more than six months is authorized.
- A legislature’s decision to label an offense a misdemeanor rather than a felony does not control the constitutional jury-trial analysis.

## Conclusion

The Court held that a defendant charged with an offense authorizing more than six months’ imprisonment has a constitutional right to a jury trial, and New York could not deny that right for a charge carrying a one-year maximum sentence.


Baldwin v. New York, 399 U.S. 66 (1970)