Groppi v. Wisconsin
Headline: Court invalidates Wisconsin rule barring venue changes in misdemeanor trials, vacates conviction, and requires courts to allow defendants to show local prejudice to secure a fair jury.
Holding: The Court held that a state law that categorically prevents a change of venue in misdemeanor prosecutions is unconstitutional because it denies defendants the chance to prove local prejudice and obtain a fair, impartial jury; conviction vacated.
- Requires courts to consider venue-change requests in misdemeanor cases when local prejudice is alleged.
- Gives defendants opportunity to present proof of prejudicial publicity or bias.
- Permits vacation of convictions when a defendant is denied chance to show prejudice.
Summary
Background
A Roman Catholic priest was arrested in Milwaukee during civil disturbances and charged with resisting arrest, a misdemeanor. His lawyers asked the trial court to move the case to another county because of massive local news coverage and community prejudice, or at least to let them present proof of the publicity’s effect. The trial judge denied the request, saying Wisconsin law allowed venue changes only for felony charges. The jury convicted him and the state supreme court affirmed.
Reasoning
The Court asked whether a State may categorically refuse a venue change just because the charge is a misdemeanor. It held that the Fourteenth Amendment requires a jury trial that is fair and impartial, and a law that forecloses any opportunity to show local prejudice violates that guarantee. The Court relied on earlier cases showing that extreme local prejudice can make a fair jury impossible and therefore that venue changes must be available when needed.
Real world impact
The decision requires courts to permit defendants in misdemeanor prosecutions to try to prove that local prejudice would prevent a fair jury. The case was vacated and sent back so the defendant can attempt to offer evidence of prejudice; if he cannot show it, the conviction may be reinstated.
Dissents or concurrances
One Justice joined the judgment but stressed the record lacked proof and the remand gives the defendant a chance to make his case; another Justice dissented, arguing venue changes are not constitutionally required and other safeguards may suffice.
Opinions in this case:
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?