Bloom v. Illinois
391 U.S. 194 (1968)
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Rule of Law:
The Sixth Amendment right to a jury trial, as applied to the states through the Fourteenth Amendment, extends to prosecutions for serious criminal contempts. Where no maximum penalty is legislatively defined, a punishment of two years imprisonment is considered a serious offense triggering this right.
Facts:
- The putative testator, a client of petitioner Bloom, died on July 6, 1964.
- After the testator's death, Pauline Owens, a practical nurse for the decedent, hired Bloom to prepare a will.
- Bloom drafted a will in the deceased's name and falsely dated it June 21, 1964, to predate the death.
- Bloom knew at the time of its creation that the will was fraudulent.
- Bloom presented the fraudulent will for admission to probate in the Circuit Court of Cook County, Illinois.
Procedural Posture:
- The State's Attorney of Cook County filed a complaint in the Circuit Court of Cook County, a state trial court, charging Bloom with criminal contempt.
- At trial, Bloom's timely motion for a jury trial was denied.
- The trial court found Bloom guilty of criminal contempt and sentenced him to 24 months in prison.
- Bloom, as appellant, directly appealed his conviction to the Illinois Supreme Court.
- The Illinois Supreme Court affirmed the conviction, finding no right to a jury trial for criminal contempt under state or federal law.
- The U.S. Supreme Court granted Bloom's petition for a writ of certiorari.
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Issue:
Does the constitutional guarantee of a right to a jury trial in serious criminal cases apply to a state prosecution for criminal contempt where the punishment imposed is a two-year prison sentence?
Opinions:
Majority - Justice White
Yes. The constitutional guarantee of a right to a jury trial applies to serious criminal contempts, and a two-year sentence qualifies as serious. Criminal contempt is a crime in the ordinary sense, and there is no substantial difference between serious contempts and other serious crimes that would justify denying a jury trial. The potential for judicial abuse is particularly high in contempt cases, as the contemptuous act often challenges the court's authority directly, making the jury an essential check against arbitrary power. While petty contempts (typically punished by sentences of six months or less) do not require a jury trial, a two-year sentence is a serious penalty that triggers the protections of the Sixth and Fourteenth Amendments.
Dissenting - Justice Harlan
No. The Court should not impose the federal jury trial rule on state criminal contempt proceedings. This decision improperly extends the holding of Duncan v. Louisiana, which itself wrongly imposed a federal procedural rule on the states that is not fundamental to procedural fairness under the Fourteenth Amendment. It is inconsistent for the Court to now extend this rule to criminal contempt, an area where it had previously declined to do so, thereby further eroding the principles of federalism.
Concurring - Justice Fortas
Yes. The Due Process Clause of the Fourteenth Amendment requires states to provide a jury trial in prosecutions for serious, non-petty offenses, which includes the criminal contempt charge in this case. However, while the fundamental right to a jury trial applies to the states, not all ancillary federal rules, such as the requirements for a 12-person jury or a unanimous verdict, should be automatically imposed. The principle of federalism allows states latitude to create their own procedures so long as they meet the fundamental fairness requirements of due process.
Analysis:
This decision significantly curtailed the historical power of judges to summarily punish for contempt of court, overturning a long-standing rule that treated contempt as a special category outside the scope of the Sixth Amendment. By aligning the right to a jury trial for serious contempts with that for other serious crimes, the Court established the severity of the penalty as the key determinant of an offense's constitutional status. This ruling provides a critical procedural safeguard against the potential for judicial bias or overreach in contempt proceedings, reinforcing the jury as a check on judicial power.
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