Robert Baldwin v. State of New York. Johnny Williams v. State of Florida

Background

These cases came from New York and Florida. In Baldwin a New York City practice allowed misdemeanor cases punishable by up to one year to be tried without a jury. In Williams Florida authorized six-person juries for most crimes. The two cases asked whether the Constitution requires jury trials in those situations and whether a jury must have twelve members.

Reasoning

Relying on the Court’s prior incorporation of the jury right to the States, the Court held in Baldwin that New York City may not try misdemeanors carrying up to a year in jail without offering a jury. In Williams the Court held that Florida’s six-member jury law satisfies the same constitutional guarantee when applied to the States. Taken together, the Court concluded that the Constitution does not require twelve-member juries in criminal trials.

Real world impact

Because of the rulings, New York City must provide jury trials for covered misdemeanors, while Florida may continue using six-person juries. The opinion notes practical effects, including likely increases in jury selection and courtroom delays in jurisdictions like New York City that previously used non-jury procedures for many cases. The decisions also affect expectations about jury size in federal and state trials.

Dissents or concurrances

Several Justices protested parts of the result. Justice Harlan dissented in Baldwin, arguing the Court should preserve historic jury protections and warning the rulings dilute federal constitutional safeguards and could worsen court backlogs; Justice Stewart expressed similar reservations and joined parts of that view.