SALT LAKE CITY — The Utah Supreme Court has ruled that a traffic violation does not mean you are entitled to a right to a trial by jury.
The Court rejected a demand by Santiago Steven Maese, who faced two class C misdemeanor charges of failure to signal and failure to obey traffic control devices. According to the ruling, Maese was cited by the Utah Highway Patrol for crossing the double-white line for the HOV lane on I-15, and crossing several lanes without signaling.
Maese went to South Salt Lake’s Justice Court where prosecutors made them infractions, but he challenged their authority and insisted he be tried by a jury. He argued it was his constitutional right. But two lower courts rejected his demand.
In the Court’s ruling, Justice John Pearce wrote that a right to a jury trial is in the state’s constitution, but it’s not very clear about what offenses guarantee it.
“Although it is difficult to peer back more than one hundred years and know with great certainty the parameters of what did and did not trigger a jury trial in 1895, we know that shortly after statehood, juries were not available for some minor offenses that carried penalties of incarceration for fewer than thirty days and/or a small fine,” he wrote. “While we leave open the possibility that future cases and additional historical evidence might provide us the opportunity to refine our understanding of the scope and limitations of the right to a jury trial, we conclude that the Utah Constitution does not guarantee Maese a jury trial for his traffic violations.”
Justice Pearce said the state’s history does not explicitly state what a “criminal prosecution” is that triggers a right to a jury trial. The justices of the Utah Supreme Court reviewed documents from the 1800s to reach the conclusion.
“When we look to the historical record, we hope that it resembles a Norman Rockwell painting—a poignant, straightforward, and easy to interpret representation. But frequently it does not. In some cases, like this one, the historical record is more like a Jackson Pollock,” he wrote. “And we find ourselves staring at the canvas in hopes of finding some unifying theme.”
In its ruling, the Utah Supreme Court ultimately drew the line at offenses that mean less than 30 days incarceration or a minor fine.
In his own opinion, Justice Thomas Lee said he agreed with the overall conclusions of his colleagues but “I would instead hold only that Maese has failed to carry his burden of establishing a constitutional right to a jury trial for an offense (here, an infraction) for which there is no risk of incarceration.”
Read the Utah Supreme Court ruling here: