DeStefano v. Woods

Background

One case involves a man in Oregon convicted of armed robbery in 1962; Oregon law allowed conviction when 10 of 12 jurors agreed, and he later asked to undo his conviction arguing the verdict need not be unanimous. The other involves a man in Illinois found guilty of criminal contempt and sentenced to three concurrent one-year terms; he argued he had been denied a jury trial. Both men lost in state courts and sought federal relief, and their claims raised questions from recent decisions about the right to jury trials in serious state cases and contempts.

Reasoning

The Court considered whether its recent rulings requiring jury trials in serious state criminal cases and in serious contempts should apply to convictions that were already final. Using the three Stovall factors—the purpose of the new rules, how much officials relied on the old rules, and the impact of applying the new rules retroactively—the Court concluded that the Duncan and Bloom decisions should operate only prospectively. It explained that many states had relied on prior law, that applying the new rules to past convictions would disrupt many cases, and that the benefits of retroactivity were limited. The Court therefore affirmed the denials of relief for these petitioners and declined to rule retroactively on related questions, such as whether unanimity or jury trials for one-year contempts must be required in already-final cases.

Real world impact

People convicted in state trials that ended before May 20, 1968 will generally not get relief based on Duncan and Bloom. States that relied on prior rules avoid large-scale retrials. Future trials beginning after that date must follow the Court’s newer jury-trial standards.

Dissents or concurrances

Justice Douglas, joined by Justice Black, dissented and argued the new jury-trial protections should apply retroactively, which would have allowed many past convictions to be revisited.