United States v. Wood

Background

A man convicted of petit larceny in the District of Columbia was tried before a jury that included several federal and District employees and a recipient of a Civil War pension. His lawyer objected that these people were interested in the Government and should be disqualified, but the trial court applied the Act of August 22, 1935, which made many government employees and pension recipients eligible for jury service. The Court of Appeals reversed, holding such employees were disqualified in criminal cases, and the Supreme Court agreed to review the question.

Reasoning

The Justices asked whether the Sixth Amendment forbids Congress from allowing government workers to serve as jurors in criminal trials. The Court examined English and colonial practice and earlier decisions, including Crawford v. United States, and concluded there was no clear historical rule that government employment created an absolute, legal presumption of bias. The Court held that Congress may change old common-law rules and that the statute reasonably enlarged the eligible jury pool. The opinion emphasized that courts must still investigate and exclude jurors for actual bias when evidence shows it.

Real world impact

The ruling makes thousands of federal and District employees eligible for jury duty in the District of Columbia, easing the empaneling of juries and reducing the need to draw on other citizens. It leaves trial judges free to question and disqualify any juror who shows actual partiality, so the decision does not eliminate case-by-case protections for defendants. Congress’s change to the law was treated as a reasonable legislative response to a local need and not a violation of due process.

Dissents or concurrances

Three Justices disagreed and would have followed Crawford, holding that government employment should disqualify a person from jury service in criminal trials; they would have affirmed the Court of Appeals and upheld the reversal.