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Sixth Amendment-Request for Jury Trial

By: WISCONSIN LAW JOURNAL STAFF//June 24, 2024//

Sixth Amendment-Request for Jury Trial

By: WISCONSIN LAW JOURNAL STAFF//June 24, 2024//

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7th Circuit Court of Appeals

Case Name: United States of America v. Seldrick Carpenter

Case No.: 23-3295

Officials: Easterbrook, Brennan, and Scudder, Circuit Judges.

Focus: Sixth Amendment-Request for Jury Trial

Seldrick Carpenter was on supervised release following a federal conviction for distributing fentanyl. After his mother’s death, Carpenter began using drugs and acting in defiance of his probation terms. When behavioral therapy proved ineffective, his probation officer sought to revoke his release. Carpenter was also suspected of arson involving a car. The Probation Office alleged multiple violations including arson, property damage, intimidation, and battery. Carpenter requested a jury trial under the Sixth Amendment and Article III, § 2, cl. 3, but the district court denied this, proceeding without a jury. He was found guilty of violations and had his supervised release revoked, receiving a 30-month prison term.

The Seventh Circuit had to decide whether a revocation proceeding under 18 U.S.C. § 3583(e)(3) constitutes a “trial of [a] crime” or a “criminal prosecution” under those clauses. Agreeing with the district court, the appeals court ruled it did not. It concluded that neither the Sixth Amendment nor Article III, § 2 guarantee a jury trial in such hearings; instead, defendants like Carpenter are entitled only to procedures outlined by Federal Rules of Criminal Procedure and the Due Process Clause of the Fifth Amendment. The court also dismissed Carpenter’s argument that Article III, § 2 could extend to proceedings beyond the Sixth Amendment’s scope, affirming the district court’s decision.

Affirmed.

Decided 06/17/24

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