The defendant was tried before the police court of the District of Columbia for selling, as a second-hand dealer, unused return-trip railroad tickets without a license, contrary to an Act of Congress. The act provides for a maximum penalty of $300 fine or ninety days in jail. The defendant was denied a jury trial. The Court of Appeals for the District of Columbia found the defendant entitled to a jury trial. On appeal to the United States Supreme Court, it was held by a majority of the Court, that the Federal Constitution does not guarantee the defendant a jury trial in a prosecution for this offense. District of Columbia v. Clawans, (U.S. 1937) 57 S. Ct. 660.
James H. Roberton,
CONSTITUTIONAL LAW- RIGHT TO JURY TRIAL - PETTY STATUTORY OFFENSES,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol35/iss8/16