Giaccio v. Pennsylvania

Background

A man named Giaccio was tried in Pennsylvania for wantonly pointing or firing a gun. A jury found him not guilty on both charges, but under an 1860 state law the jury also voted that he should pay prosecution costs for one charge, and the court ordered payment or jail until payment. Lower state courts reinstated that order after a trial court had set it aside as unconstitutional.

Reasoning

The Court addressed whether the 1860 law meets the Constitution’s promise of fair legal process (the Fourteenth Amendment’s Due Process Clause). The majority held the statute unconstitutional because it gives juries no clear standards for deciding who must pay costs and even authorizes jailing an acquitted person until payment. The Court rejected the State’s argument that calling the rule “civil” avoids constitutional limits and pointed to vague phrases like “misconduct” or “reprehensible” that leave juries free to act arbitrarily.

Real world impact

The ruling voids Pennsylvania’s cost statute as written and prevents enforcing a judgment that would force payment or jail under that law. It limits state laws that allow juries to impose costs or penalties on people found not guilty without definite rules to guide those decisions. The decision leaves intact ordinary sentencing practices where juries punish people already found guilty within clear legal limits.

Dissents or concurrances

Two Justices wrote concurring opinions: one emphasized that allowing any punishment after acquittal violates basic fairness, and another said the Due Process Clause forbids imposing penalties or costs on a person the jury has found not guilty of the charges.