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In Re Royall

• 1887 • 125 U.S. 696 • Waite Court
In re Royall is a United States Supreme Court case that addressed the issue of whether a state court could deny a defendant the right to a jury trial in a criminal case. The case involved a man named William Royall, who was charged with the crime of larceny in the state of Virginia. Royall argued that he was entitled to a jury trial under the Sixth Amendment of the United States Constitution. The Supreme Court held that the Sixth Amendment did not apply to the states, and that the state court...Open Case
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Chief Waite Court
Term: 1887
Docket: 1351
125 U.S. 696
8 S. Ct. 1392
31 L. Ed. 855
1888 U.S. LEXIS 1957

In Re Royall

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Opinion Summary
AI Abstract

In re Royall is a United States Supreme Court case that addressed the issue of whether a state court could deny a defendant the right to a jury trial in a criminal case. The case involved a man named William Royall, who was charged with the crime of larceny in the state of Virginia. Royall argued that he was entitled to a jury trial under the Sixth Amendment of the United States Constitution. The Supreme Court held that the Sixth Amendment did not apply to the states, and that the state court was within its rights to deny Royall a jury trial. The Court reasoned that the Sixth Amendment was intended to protect the rights of citizens in federal court, and that the states were free to set their own rules regarding jury trials. The Court also noted that the right to a jury trial was not absolute, and that the states could impose reasonable restrictions on the right. The Court concluded that the state court's decision to deny Royall a jury trial was reasonable and did not violate the Sixth Amendment.

Dissent Summary
AI Abstract

In re Royall was a case heard by the United States Supreme Court in which the court considered whether or not an individual could be convicted of contempt for refusing to answer questions posed during a congressional investigation. The majority opinion held that Congress had the power to punish individuals who refused to answer its inquiries, and thus affirmed the conviction of William Royall. In his dissenting opinion, Justice Field argued that Congress did not have such authority under Article I, Section 5 of the Constitution. He reasoned that since this section only gave Congress power over its own proceedings and members, it did not extend far enough to allow them to punish non-members for their refusal to testify before it. Furthermore, he argued that allowing such punishment would violate due process rights as guaranteed by both state constitutions and federal law. Ultimately, Justice Field concluded that while Congress may compel testimony from witnesses within its jurisdiction through other means (such as subpoenas), punishing those who refuse is beyond what is allowed under Article I Section 5 of the Constitution

Opinion written by Justice MRWaite
Decided: Feb 20, 1888
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