518 U.S. 322 (1996)
Petitioner Ray Lewis worked as a mail handler for the United States Postal Service.1 One day postal inspectors observed him opening several pieces of mail and pocketing the contents.2 The next day the inspectors routed test mail containing marked currency through his station, and after seeing him open the mail and remove the currency they arrested him.3
Lewis was charged with two counts of obstructing the mail in violation of 18 U.S.C. § 1701, each carrying a maximum authorized prison sentence of six months.4 He requested a jury trial, but the Magistrate Judge granted the Government's motion for a bench trial after explaining that she would not, under any circumstances, sentence him to more than six months' imprisonment.5
Lewis sought review of the denial of a jury trial. The District Court affirmed, and the Court of Appeals for the Second Circuit affirmed the judgment as well.6 The Supreme Court granted certiorari to resolve a conflict among the Courts of Appeals over the jury trial questions presented by prosecutions for multiple petty offenses.7
Whether a defendant who is prosecuted in a single proceeding for multiple petty offenses has a constitutional right to a jury trial where the aggregate prison term authorized for the offenses exceeds six months?8
The Sixth Amendment reserves the jury trial right for serious offenses only.9 An offense is serious if the legislature authorizes a maximum prison term exceeding six months.10 The legislature's judgment on the character of each offense controls, as expressed in the maximum penalty for that offense.11 Multiple counts of the same petty offense do not alter the legislative classification or convert the offenses into a single serious crime for Sixth Amendment purposes.12 Precedent at common law confirms that a defendant charged with multiple petty offenses receives no jury trial right.13
No. The established facts show that Lewis faced two counts of obstructing the mail under 18 U.S.C. § 1701, each authorizing a maximum of six months' imprisonment.14 The legislature therefore classified each offense as petty.15 The Magistrate Judge conducted a bench trial after the government moved for that procedure.16 The District Court and the Court of Appeals for the Second Circuit both affirmed the denial of a jury trial on the ground that the character of each offense remained petty.17
Because the maximum penalty per count fixes the constitutional classification, the aggregate exposure of twelve months does not trigger the jury trial guarantee.18 The Supreme Court granted certiorari precisely to resolve whether aggregation changes the analysis, and the facts demonstrate that it does not.19
Lewis possessed no constitutional right to a jury trial.20
Related opinions on this issue
Joined by Justice Breyer
Justice Kennedy wrote that this petitioner had no constitutional right to a jury trial because from the outset it was settled that he could be sentenced to no more than six months’ imprisonment for his combined petty offenses.21 He maintained that Codispoti v. Pennsylvania and Taylor v. Hayes require aggregation of sentences imposed in a single proceeding for multiple petty offenses when the total exceeds six months.22 He emphasized that the primary purpose of the jury is to interpose protection against arbitrary governmental deprivation of liberty.23
In his view the pretrial commitment by the magistrate that no sentence would exceed six months removed any actual threat of extended imprisonment and therefore eliminated the need for a jury in this particular case.24 He warned that the majority's rule permits prosecutors to evade the jury right by fragmenting charges while still exposing defendants to lengthy cumulative incarceration.25
Justice Stevens wrote that the Sixth Amendment provides that the accused is entitled to trial by an impartial jury in all criminal prosecutions.26 He argued that the Sixth Amendment text refers to criminal prosecutions rather than individual offenses, so the right attaches when the prosecution as a whole exposes the defendant to more than six months' imprisonment.27 He read Codispoti as confirming that aggregation is required once multiple counts are tried together.28
Because the two mail-obstruction counts carried a statutory maximum of twelve months, Stevens concluded that the prosecution itself was serious from its inception.29 A pretrial sentencing commitment could not retroactively strip the defendant of the jury right.30
Whether a defendant who would otherwise have a constitutional right to a jury trial may be denied that right because the presiding judge has made a pretrial commitment that the aggregate sentence imposed will not exceed six months?31
Because no jury trial right exists when a defendant is charged with multiple petty offenses, the Court did not reach the question whether a judge's pretrial commitment limiting the aggregate sentence to six months could eliminate an otherwise existing jury trial right.32
No. The established facts establish that Lewis was charged with two petty offenses.33 The Magistrate Judge announced before trial that she would impose no more than six months total.34 The Court of Appeals noted in dictum that such a commitment would not affect the jury right if one otherwise existed.35 Because the Supreme Court held that no jury right exists when only petty offenses are charged, the Court expressly declined to decide whether the magistrate's commitment could eliminate a right that would otherwise attach.36
The Court did not reach the question whether a pretrial sentencing commitment can eliminate an otherwise existing jury trial right.37
Related opinions on this issue
Joined by Justice Breyer
Justice Kennedy explained that when the trial judge commits at the outset to a sentence of no more than six months for the combined offenses, the liberty interest protected by the jury trial right is not implicated.38 He viewed the commitment as merely clarifying the legal consequence rather than depriving the defendant of any right.39 This approach aligns with the practice approved in Scott v. Illinois, where a judge's pretrial determination that no jail time would be imposed eliminated the need for appointed counsel.40
Federal Rule of Criminal Procedure 58(a)(2) similarly authorizes pretrial determinations in petty offense cases that no imprisonment will be imposed.41
Justice Stevens rejected the notion that a pretrial commitment could defeat the jury right.42 He maintained that the right attaches at the commencement of the prosecution whenever the statutory maximum for the charges exceeds six months.43 In his view a judge cannot strip the constitutional protection by promising a shorter sentence any more than the judge could do so for a single serious offense.44
He concluded that because the right attaches at the moment of prosecution, the magistrate's commitment could not retroactively eliminate the jury trial guarantee.45