Facts
- Carol Link and Debra Meltsner were charged in New York County with prostitution, a class B misdemeanor.
- The charged offense carried a maximum penalty of three months’ imprisonment.
- A state statute required class B misdemeanor trials in New York City to be tried without a jury before a single judge.
- Defendants moved pretrial for a jury trial, arguing the statute was unconstitutional as applied.
Issues
- Whether prostitution, despite a maximum three-month jail term, is a “serious” offense triggering the Sixth Amendment right to a jury trial in a state criminal prosecution.
- Whether denying jury trials for class B misdemeanors in New York City, while permitting them elsewhere in New York State, violates equal protection.
Decision
- The court granted defendants’ motion for a jury trial.
- The court held prostitution is a “serious” offense for federal jury-trial purposes notwithstanding the three-month maximum sentence.
- The court held the statutory mandate of bench trials for class B misdemeanors in New York City was unconstitutional as applied to these prosecutions.
- The court also concluded the geographic denial of jury trials in New York City for the same class of offenses available elsewhere in the state violated equal protection.
Legal Principles
- The Sixth Amendment jury-trial right applies in state prosecutions for “serious” offenses.
- Offense seriousness is not determined solely by the maximum authorized incarceration; the nature of the offense and significant non-incarceration consequences may require jury-trial treatment even when the maximum sentence is six months or less.
- A rule treating exposure above six months as automatically “serious” does not preclude finding certain offenses “serious” below that threshold based on their character and consequences.
- A state may not deny jury trials to defendants in one locality while allowing them to similarly situated defendants elsewhere for the same class of offenses, absent adequate justification, consistent with equal protection.
Conclusion
The court required a jury trial for prostitution charges in New York City, ruling that prostitution is constitutionally “serious” despite its short maximum jail term and that a statutory scheme denying jury trials in New York City for class B misdemeanors, while permitting them elsewhere in the state, could not stand under federal jury-trial and equal-protection guarantees.