Supreme Court of the United States
Destefano v. Woods
June 17, 1968392 U.S. 631
Summary
The Court held that the Sixth Amendment jury‑trial rules announced in Duncan v. Louisiana and Bloom v. Illinois apply only prospectively, so the petitioners’ convictions are not subject to reversal. It based the prospective application on the Stovall factors of purpose, reliance, and effect. Justice Douglas dissented, arguing that the right to a jury trial should be applied retroactively.
Holding
- Whether the rule in Duncan v. Louisiana requiring a jury trial in serious criminal cases applies retroactively to convictions preceding May 20, 1968.. The Duncan rule applies only prospectively and does not retroactively invalidate prior convictions.
- Whether the rule in Bloom v. Illinois extending the right to a jury trial to serious criminal contempt applies retroactively to convictions preceding May 20, 1968.. The Bloom rule also applies only prospectively and does not retroactively invalidate prior contempt convictions.
- Whether the Sixth Amendment unanimity requirement discussed in Maxwell v. Dow applies retroactively to such cases.. The unanimity requirement is not applied retroactively; prior convictions without unanimous verdicts stand.
Docket 559