Cynthia Hwang v. Township of Hillsborough
679 F. App'x 200
| 3rd Cir. | 2017Background
- Cynthia Hwang was arrested in October 2012 and tried in Bridgewater Municipal Court in June 2013 on multiple offenses (DUI, refusal to provide breath sample, failure to maintain lane, resisting arrest, cracked windshield) and convicted after a nonjury trial.
- None of the charged offenses carried a potential jail term over six months or fines over $1,000; under New Jersey law they are classified as disorderly person / petty offenses.
- Hwang sued the Townships under 42 U.S.C. § 1983, alleging among other claims that she was constitutionally entitled to a jury trial on those charges.
- The District Court dismissed her complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim.
- On appeal, Hwang argued the petty-offense exception to the Sixth Amendment jury right is unjustified and should be abandoned; she conceded controlling Supreme Court precedent was adverse.
- The Third Circuit affirmed, holding Supreme Court precedents foreclose Hwang’s claim that she had a constitutional right to a jury trial on these petty offenses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hwang had a Sixth Amendment right to a jury trial on offenses classified as petty under state law | Hwang argued the petty-offense doctrine is unjustified and the Court should abandon it; she claimed a jury right despite petty classification | Defendants argued the crimes are petty under New Jersey law and controlling Supreme Court precedent forecloses a jury right | Court held no jury right: petty-offense doctrine controls; offenses with max ≤6 months (and aggregated petty counts) do not entitle defendant to jury trial |
Key Cases Cited
- Duncan v. Louisiana, 391 U.S. 145 (recognizes petty-offense exception to Sixth Amendment jury right)
- Lewis v. United States, 518 U.S. 322 (holding aggregation of petty offenses that together exceed six months does not trigger jury right)
- Blanton v. City of N. Las Vegas, 489 U.S. 538 (reiterating category of petty offenses excluded from jury trial guarantee)
- District of Columbia v. Clawans, 300 U.S. 617 (confirming jury right does not extend to every criminal proceeding)
- United States v. Katzin, 769 F.3d 163 (3d Cir. en banc) (noting Supreme Court decisions are binding precedent)