Lewis v. United States, 518 US 322 (1996)

Postal Inspectors observed Ray Lewis, a mail carrier, open several pieces of mail assigned for delivery and pocket the envelopes' contents. The following day, the inspectors seeded Lewis' mailbag with envelopes containing marked bills, which he subsequently opened and stole.

Lewis was charged with two counts of obstructing the mail (18 U. S. C. Â§ 170l), a misdemeanor charge carrying a maximum penalty of six months jail time for each count. Over the defendant's objections, the magistrate granted the prosecution's motion for a bench trial, explaining Lewis was not entitled to a jury trial because she would voluntarily limit the sentence to no more than six months, total. The six-month cut-off was important due to the Supreme Court finding in Frank v. US, 395 US 147 (1969), and Baldwin v. New York, 399 US 66 (1970), which held that sentences of no more than six months for petty offenses may be constitutionally imposed without a jury trial. Lewis was subsequently found guilty.

Lewis appealed denial of his Sixth Amendment right to a jury trial to the US Court of Appeals for the Second Circuit, which affirmed the lower court ruling, holding that the constitutional right to a jury trial is reserved for the prosecution of serious offenses, not multiple petty charges.

Lewis appealed to the US Supreme Court, asserting that the maximum penalty for two counts of obstructing the mail could have been in excess of six months incarceration, promises from the trial judge notwithstanding, and therefore should have qualified for a jury trial pursuant to Duncan v. Louisiana, 391 US 145 (1968). In Duncan, the defendant was denied a jury trial for simple battery, a misdemeanor carrying a maximum penalty of two years prison. Although the defendant received only two months jail and a $10 fine, the Court held that the potential of serving two years in prison, together with the perception that assault is a serious crime, entitled the defendant to a jury trial.

The Court considered Lewis in light of the fact that consecutive sentences of six months for each of two counts of obstructing the mail could have effected a jail sentence of one year, six months in excess the threshold generally held to trigger a right to trial by jury.

The Court held that the potential length of imprisonment alone was insufficient to warrant a jury trial, and that the character of the crime must be considered as well. In the opinion of the Court, Justice O'Connor wrote:

"The Sixth Amendment reserves the jury trial right to defendants accused of serious crimes. As set forth above, we determine whether an offense is serious by looking to the judgment of the legislature, primarily as expressed in the maximum authorized term of imprisonment. Here, by setting the maximum authorized prison term at six months, the Legislature categorized the offense of obstructing the mail as petty. The fact that petitioner was charged with two counts of a petty offense does not revise the legislative judgment as to the gravity of that particular offense, nor does it transform the petty offense into a serious one, to which the jury trial right would apply."

O'Connor distinguished Lewis from Codispoti v. Pennsylvania, 418 US 506 (1974), in which the Supreme Court ruled the defendants, convicted of multiple counts of contempt of court carrying a penalty of six months jail each (aggregating to approximately three years for each defendant), were entitled to a jury trial because the Legislature had not made clear whether contempt was considered a serious or petty offense.

The decision of the lower courts was affirmed.

Justices Stevens and Ginsburg dissented on the grounds that the potential aggregate sentence, alone (as in Codispoti) was sufficient to warrant the Sixth Amendment right to a jury trial, and that the judgment contradicted Baldwin v. New York,(1970), where the Supreme Court held a Class-A misdemeanor (jostling) carrying a maximum sentence of one year in jail. Baldwin drew a bright line by indicating sentencing guidelines alone should dictate whether a crime was considered serious enough to warrant a jury trial: "no offense can be deemed "petty" for purposes of the right to trial by jury where imprisonment for more than six months is authorized"

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