Jean-Baptiste Bado v. US (en banc), 186 A.3d 1243

Jean-Baptiste Bado, a noncitizen asylum applicant, was charged with three counts of misdemeanor sexual abuse of a minor in D.C.; he demanded a jury trial which the trial court denied and a bench trial followed.
At trial Bado was acquitted on two counts and convicted on one; he received 180 days, $50 to victims fund, and ten years of sex-offender registration. The government initiated removal proceedings based on the conviction.
The charged offense carries a maximum 180-day jail term under D.C. law, placing it below the Supreme Court’s six‑month Baldwin threshold for a presumptively petty offense.
The central legal question (decided en banc) was whether the Sixth Amendment requires a jury trial when a conviction for a petty-range offense also exposes a noncitizen to removal/deportation.
The en banc D.C. Court of Appeals held that deportation, when considered together with a six‑month‑or‑less incarceration exposure, overcomes the Blanton presumption that the offense is petty and thus entitles the defendant to a jury trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Sixth Amendment requires a jury trial where a noncitizen faces deportation as a consequence of conviction for an offense punishable by ≤6 months incarceration	Bado: Deportation is an additional statutory penalty that, combined with 180 days' incarceration, is so severe it renders the offense "serious" under Blanton and entitles him to a jury trial	Government: Deportation is civil/collateral, imposed by Congress (not the local legislature), not a criminal punishment to be considered in Blanton; practical and institutional difficulties counsel against counting removal	Court (majority): Deportation is a severe statutory penalty "enmeshed" in criminal convictions; viewed with the 180‑day maximum it overcomes the petty‑offense presumption and triggers the Sixth Amendment right to a jury trial

Baldwin v. New York, 399 U.S. 66 (constitutional dividing line: imprisonment >6 months makes an offense "serious")
Blanton v. City of N. Las Vegas, 489 U.S. 538 (test for when ≤6 months imprisonment plus other penalties render an offense "serious")
Padilla v. Kentucky, 559 U.S. 356 (deportation is a particularly severe consequence closely tied to criminal conviction)
Sullivan v. Louisiana, 508 U.S. 275 (denial of structural jury-trial rights requires reversal)
Duncan v. Louisiana, 391 U.S. 145 (Sixth Amendment jury-trial guarantee for serious offenses)
United States v. Nachtigal, 507 U.S. 1 (Blanton framework applied; additional penalties did not convert petty offense)
Frank v. United States, 395 U.S. 147 (legislative choice of maximum penalty informs seriousness)
I.N.S. v. Lopez‑Mendoza, 468 U.S. 1032 (removal proceedings are not criminal prosecutions for exclusionary‑rule purposes; distinct context cited by parties)
Fong Yue Ting v. United States, 149 U.S. 698 (historical characterization of deportation as severe/banishment)