Blanton v. City of North Las Vegas

Background

Two men charged with driving under the influence in North Las Vegas asked for jury trials but were denied in municipal court. One appealed and was twice denied, while the other’s case produced mixed rulings in the state courts. The Nevada Supreme Court held that the Federal Constitution does not guarantee a jury trial for first-time DUI offenses because the maximum jail term is six months and fines and other penalties are limited. The U.S. Supreme Court agreed to review the question and now affirms the Nevada decision.

Reasoning

The central question was whether a person charged with first-time DUI in Nevada has a constitutional right to a jury trial. The Court explained that offenses carrying more than six months in jail generally require a jury, while those with six months or less are presumed “petty.” The Court looked at the full package of penalties Nevada imposes — up to six months in jail, fines up to $1,000, a 90-day license suspension, required alcohol classes, and possible 48 hours of identifiable community service — and concluded those added penalties do not plainly show the legislature viewed DUI as “serious.” Because the maximum jail time stays at six months, the Constitution does not guarantee a jury here.

Real world impact

People charged with a first-time DUI in Nevada can be tried without a jury. The decision rests on the specific penalties Nevada set, so states that authorize longer jail terms or much larger penalties could reach a different result. The ruling leaves open the possibility that repeat-offender cases with heavier penalties might require a jury.