In 2012, a Minnesota man admitted to having a sexual encounter with a 14-year-old girl. According to court documents, he waived his right to a jury trial while facing one count each of third-degree and fourth-degree criminal sexual conduct. After the defendant entered the waiver, the state amended the complaint to add a first-degree charge as well. The man was convicted of all three criminal sexual conduct charges and sentenced to 153 months in prison.
Citing the fact that the district court never obtained a new jury waiver after adding the first-degree charge, the man appealed his case. The state court of appeals upheld the conviction, but the Minnesota Supreme Court reversed it and ordered a new trial.
A defendant’s rights
Under the Federal Rules of Criminal Procedure, a defendant may enter a waiver to jury trial. This process includes entering a plea bargain, which both the prosecution and defense must approve in order to pass. According to a report in The Wall Street Journal, guilty pleas now account for 97 percent of all resolved federal cases as opposed to just 84 percent in 1990. The growing popularity of waiving a jury trial could be explained by several advantages it offers, including the following:
- Facing lesser charges
- Incurring lighter sentencing
- Quickly resolving the matter
- Having fewer or less serious charges on a permanent record
Under Minnesota law, a defendant is permitted to waive a jury trial provided that the court approves the plea and determines that the person has knowingly waived that right. People may also waive their right to trial in Minnesota if the prosecution seeks an aggravated sentence or if there is a chance that prejudicial publicity could play a role in the proceedings.
In the case concerning the man whose criminal complaint was amended following his plea, the Minnesota Supreme Court correctly ascertained that a new waiver should have been obtained. In his written opinion, one of the justices noted that the defendant never received a copy of the complaint with the added first-degree charge nor was he aware of the change until after he was found guilty. Therefore, the justice opined, the district court committed an error and violated the defendant’s rights.
The high court ruled that the existing state law requires a new jury trial waiver if the state chooses to amend a complaint after the initial waiver is entered. Doing otherwise jeopardizes the integrity and fairness of the judicial system.