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Keywords

appealtrialwillcommon lawjury trial
statutetrialwillrespondentjury trial

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District of Columbia v. Colts, 282 U.S. 63, 51 S.Ct. 52, 75 L.Ed. 177

Facts

William H. Colts was charged with operating a motor vehicle recklessly at a speed greater than twenty-two miles per hour, which was deemed dangerous to property and individuals. He was tried without a jury after his demand for a jury trial was denied. The Court of Appeals reversed the conviction, stating that under the Constitution, Colts was entitled to a jury trial due to the serious nature of the offense.

‘An information filed in the Police Court of the District of Columbia charged the respondent, Colts, with having operated upon various streets, contrary to the statute set forth below, ‘a certain motor vehicle at a greater rate of speed than twenty-two miles an hour over said public highway(s) recklessly…’

Issue

Was William H. Colts entitled to a jury trial for the charge of reckless operation of a motor vehicle?

‘Was William H. Colts entitled to a jury trial for the charge of reckless operation of a motor vehicle?’

Rule

The Constitution provides that the trial of all crimes, except in cases of impeachment, shall be by jury. The determination of whether an offense is a crime requiring a jury trial or a petty offense triable without a jury depends on the nature of the offense.

‘The Trial of all Crimes, except in Cases of Impeachment, shall be by Jury.’

Analysis

The court analyzed the nature of the offense charged against Colts, determining that it was not merely a petty offense but rather a serious crime that could endanger lives and property. The court referenced the common law and previous cases to support the conclusion that such an offense is indictable and thus requires a jury trial.

‘The offense here charged is not merely malum prohibitum, but in its very nature is malum in se.’

Conclusion

The Supreme Court affirmed the decision of the Court of Appeals, holding that Colts was entitled to a jury trial for the charge against him.

‘Judgment affirmed.’

Who won?

William H. Colts prevailed in the case because the court agreed with the appellate court's ruling that he was entitled to a jury trial based on the serious nature of the offense.

‘the court agreed with the appellate court's ruling that he was entitled to a jury trial based on the serious nature of the offense.’

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