This article is written by Monesh Mehndiratta, a law student at Graphic Era Hill University, Dehradun. The article explains the Sixth Amendment to the US Constitution, which prescribes the rights of an accused. It further elaborates all the rights mentioned therein in detail along with case laws. 

It has been published by Rachit Garg.

Introduction

Have you ever wondered why a justice system is so important for any country? Why is it necessary to give certain rights to an accused? What rights have been given to them? 

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If you do not know the answer to these questions, you need not worry. This article will help you understand that, in a country, the justice system plays an important role. It serves justice to those against whom any kind of wrong has been committed. For this purpose, the elements of the justice system have to be fair and free from any kind of discrimination. The accused have the right to a fair and impartial trial, for which judges are required to be neutral and impartial. Most of the countries in the world have recognized certain human rights, which include the rights of the accused as well. One such country is the United States of America, wherein the rights of accused persons have been recognized and enshrined in the Constitution. These rights were added to the Bill of Rights through the Sixth Amendment. 

The Sixth Amendment of the United States Constitution has a long and varied history. It has been interpreted over the years in different ways and has had a significant impact on criminal justice proceedings in the United States. In this article, we will look at what the Sixth Amendment is and its various components, like the right to a speedy trial, the right to a public trial, an impartial jury, etc. It further provides how the amendment has been interpreted over the years with the help of landmark court decisions. 

What is the Sixth Amendment

The Sixth Amendment is part of the United States Bill of Rights and was adopted in 1791. It states that the accused in the US enjoy the following rights:

  • Right to a speedy trial. 
  • Right to public trial.
  • Trial by an impartial jury. 
  • Right to be informed about the nature of charge and reason of accusations.
  • Right to confront the witness. 
  • Right to call witnesses in order to prove the accused’s innocence. 
  • Right to assistance. 

The Sixth Amendment is also closely related to the Fifth Amendment, which deals with the right to due process of law. It gives the accused the right to remain silent in cases of capital and infamous crimes. It also provides rights against double jeopardy and guarantees that he will not be deprived of his life, liberty, or property without following due process. Both amendments guarantee a fair trial for those accused of a crime. In addition, the Sixth Amendment also gives the accused the right to a speedy trial, as well as the right to an impartial jury and the right to the assistance of counsel.

Interesting facts about the Sixth Amendment

The Sixth Amendment was part of the Bill of Rights and added to the US Constitution in 1791. Here are some interesting facts about the amendment:

  • A trial can be conducted at another place instead where the crime was committed in order to have an impartial jury.
  • The defendants under the Amendment are also entitled to represent themselves on their own without any lawyer. 
  • It is also known as “Amendment VI”. 
  • Under the Amendment, a witness can be called to testify and come to court forcefully which is known as “subpoena”. 

History of the Sixth Amendment

The history of the Sixth Amendment can be traced back to English common law. The principles on which the Sixth Amendment is based and the rights guaranteed therein existed in England and were also seen in its colonies. During the 12th century, trials were done by the old, respected people on the defendant’s side or by neighbors who also decided the fate of the accused. These were also known as the earliest juries. However, these trials were not impartial, and even the government of the time either fined or punished the jurors for not finding the defendant guilty. This was the situation until 1670, when public outrage was witnessed after a defendant was found to be innocent by the juror and he was punished for the same. This case is known as Bushell’s case, which also put an end to such punishments. 

American colonies enjoyed more rights than their counterparts. A set of fundamental laws was established in West Jersey in 1676, guaranteeing a public trial to the accused by a jury consisting of good and lawful men. Similarly, Pennsylvania framed a government charter known as the “Frame of Government of Pennsylvania” in 1683, which guaranteed the right to speedy trial to the people. After the war between Great Britain and America in 1775, most of the colonies in the USA adopted the Bill of Rights by 1781, which also included the right to a jury trial. In 1781, the Articles of Confederation were ratified, creating a union of colonies where most of the governmental power was enjoyed by the states. After the adoption of the US Constitution, a strong national government was established with division of power among the three branches, namely, the legislature, executive, and judiciary. 

In the new Constitution, several rights were incorporated later. James Madison, the fourth President of the USA, spent congress sessions writing and promoting certain amendments that later were incorporated as the Bill of Rights. One of the proposals among these was the protection of the rights of the accused, which was taken and made a part of the constitution by the Sixth Amendment. 

The constitutional right to a speedy trial

The Sixth Amendment guarantees the accused the right to a speedy trial. This right is intended to prevent the accused from being held in pre-trial detention for an unreasonable amount of time. In the case of United States v. Becker (2000), the Supreme Court established a four-pronged test to determine if a criminal trial was conducted in a timely manner. According to this test, four factors are considered to determine whether the trial was speedy or delayed:

  • Length of the delay.
  • The reason for the delay.
  • Whether the defendant was prejudiced in any way. 
  • Whether the defendant waived the right to a speedy trial.

The concept of a speedy trial was interpreted for the first time in the case of Beavers v. Haubert (1905). In this case, the defendant was charged with crimes in two different places, i.e., New York and the District of Columbia. The State Court in New York permitted the District of Columbia to conduct the trial first. The defendant argued that his right to a speedy trial has been violated in this case due to trials at two different places. The Supreme Court held that every case must be judged on the basis of its own circumstances. It was observed that the delay in this case was caused by another trial, so the public’s right to try the defendant outweighed his right to a speedy trial. 

In another case, Klopfer v. North Carolina (1967), the defendant was charged with an offense of criminal trespass. His charge was dismissed because the jury was not able to decide his case, but they retained their right to charge him again at any time. It was argued that this decision of the jury violated his rights mentioned in the Sixth Amendment. The Supreme Court in this case gave judgment in favor of the accused and held that keeping him under suspicion for an indefinite period violates his right to a speedy trial and is invalid. On the other hand, a defendant in Barker v. Wingo (1972) gave up his right to a speedy trial due to his own fault in objecting to the continuances to delay his trial. In this case, the prosecution sought 16 continuances in Barker’s trial. Barker did not object to the first eleven continuances but filed a motion on the twelfth continuance to dismiss his trial on the grounds of speedy trial, which was rejected. He further did not object to other continuances and was finally convicted. The Supreme Court gave a balancing test to determine whether the defendant’s right to speedy trial has been violated or not. It was further held that the requirement of public trial is not absolute and that a closed trial can be requested  by the government and the defendant in some cases. 

Further, in the case of Doggett v. United States (1992), there was a delay of eight and a half years between the arrest or indictment of the accused and his prosecution. The Supreme Court observed this extraordinary delay and ruled that the government was to be blamed for the same. 

Scope and applicability of the right to a speedy trial

The right to a speedy trial can be considered as the most rights preserved by the Constitution of the US. In the case of Klopfer v. North Carolina (1967), the Supreme Court held that this right is one of those fundamental liberties that is applicable to states by virtue of the Fourteenth Amendment to the Constitution. However, the major question with respect to its applicability is when this right will be detached or violated, and what are the remedies.  

In the case of United States v. Marion (1971), it was held that the protection given by this right can only be activated when the criminal prosecution has started and extends to only those who have been accused of the crime. Further, in the case of Betterment v. Montana (2016), it was held by the US Supreme Court that this right to a speedy trial detaches when the accused has been convicted. It does not provide protection from delays in sentencing. 

The statutory right to a speedy trial

In addition to the constitutional right to a speedy trial, a number of states have enacted statutory rights to a speedy trial. The federal law dealing with this right is the Speedy Trial Act of 1974. On the other hand, different states have different laws that provide time limits for the trial and sentencing. For example, Section 30.30 of the Criminal Procedure Law (CPL) in New York deals with time limits for trials in different offenses. These statutes are intended to provide additional protection to the accused by limiting the length of pre-trial detention. Statutory rights to a speedy trial vary from state to state and may include factors such as the amount of time a defendant can be held in pre-trial detention, the amount of time a defense attorney has to file motions, and the amount of time a court has to render a decision.

The right to a public trial

The Sixth Amendment also guarantees the accused the right to a public trial. This right is intended to ensure that the proceedings are conducted in a fair and open manner. It is an important safeguard against corruption and abuse of the judicial system, which also prevents the officers from using their power arbitrarily. Moreover, when a trial is conducted in the open, it also helps in creating awareness and fear in the minds of people not to commit crimes in the future.  

In the United States, trials are usually open to the public, with some exceptions, such as cases involving minors or other sensitive matters. In addition, the accused may request that their trial be closed to the public if they feel that their right to a fair trial would be compromised by an open courtroom.

The Sixth Amendment tries to increase the confidence of the public in the justice system by giving its citizens the right to a public trial. It prohibits closed and secret trials, unlike the one that happened in the Star Chamber in England in the 16th century. The term ‘star chamber’ means a secret court proceeding that is used to persecute people. It consisted of a committee of council of the English King and was reorganized in 1487 to include four high officers of state, a temporal lord of council, and two justices of the Westminster Court. It had the power to impose penalty, whipping, prison sentences but not death sentences. Originally, it was famous for protecting people from their oppressors, but later it abused its powers and tortured people. In 1641, the court was finally abolished.

The right to a public trial is not absolute in nature and has certain restrictions. The court has a right to exclude the public from a trial if a witness is not comfortable due to the presence of the public. But this exclusion is temporary. It can also limit the number of spectators witnessing a trial. In the case of Waller v. Georgia (1984), the Court of Georgia closed a part of the trial in order to protect the right to privacy of one of the witnesses. The case was closed after seven days, during which less than three hours were spent on issues involving the witness. The Supreme Court in this case observed that this step violated the Sixth Amendment and ruled that the closure of a trial must not be longer than the necessary time limit. 

The right to an impartial trial

The Sixth Amendment also guarantees the accused the right to an impartial trial. This right is intended to ensure that the accused receives a fair trial and is not prejudiced by bias on the part of the jury.

The right to an impartial trial is composed of several different components. These are:

  • the right to a jury trial,
  • the right to jury impartiality,
  • the right to pretrial impartiality,
  • the right to voir dire of the jury.
  • the right to the selection of jurors,
  • the right to challenge jurors, 
  • the right to an attitude toward the death penalty, 
  • the right to a certain number of jurors, etc. 

All these rights help ensure that the principles of a fair trial are followed properly and that no state violates any of these principles. It also ensures that the accused person is aware of their rights and exercises them. 

Right to jury trial

The objective of a jury trial is to prevent abuse of powers by the judges or prosecutors by placing simple citizens between the accused and the government. This right to trial by jury depends largely on the nature of the offense. Most petty offenses are kept outside its purview. Moreover, this right does not extend to juvenile proceedings. This was observed in the case of McKeiver v. Pennsylvania (1971). 

The previous position of the jury trial meant a trial by jury as adopted and applied by common law. In the case of Callan v. Wilson (1888), it was held that a trial by jury consisting of 12 people must be done during the first court proceeding and not at the appellate stage. However, as the right extended to states, it was indicated that the standards of a jury trial were open to re-examination.

Another important thing to be noted is that this right to a jury trial can be waived by the defendant depending upon the jurisdiction of the court. For example, in a federal district court, in order to waive the right, the same must be approved by the court and the prosecutor. However, it cannot be waived if there is a possibility of punishing the defendant with the death penalty.

Jury impartiality

The Sixth Amendment provides that the trial must be conducted by an impartial jury. To achieve the goal of a fair trial, it is necessary that the judges be neutral and unbiased  towards any party. 

In the case of Pena-Rodriguez v. Colorado (2017), one of the jury members made some biased statements against the ethnicity of the defendant. The Supreme Court ruled that a court must investigate the verdict of the jury after it has been delivered to determine whether it was based on racial bias. In order to prove this, the defendant must prove that racial bias was a significant factor that motivated a juror’s vote. 

Selection of jurors

Earlier, a jury consisted of twelve people, like the one in England. This was also reaffirmed by the Supreme Court in the case of Patton v. United States (1930). However, this decision was overruled by the US Supreme Court in the case of Williams v. Florida (1970), wherein a jury of 12 people was called a historical accident and that even six people could serve the purpose of a jury. Further, in the case of Apodaca v. Oregon (1972), it was held that the unanimous verdict in criminal trials by states is not a requirement of the Constitution. The importance lies in the common sense of judgment by jury between the accused and the accuser, and to achieve this purpose, it is not necessary to pass a unanimous verdict. 

The selection of a jury is not an easy task. A jury is selected at the start of the trial by defense and prosecution lawyers from a large group of potential jurors. Attorneys from both sides ask the members of the group certain questions, and the judge may exclude certain members for different reasons. This process is known as voir dire for the jury. In the case of Connors v. United States (1895), potential jurors were asked about their preferences in the political party and to which party they belonged. However, the judge objected to the question, stating that this information is irrelevant to the case and cannot form a basis for deciding the case by the jury. 

Place of trial – jury of the vicinage

Section 2 of Article III of the US Constitution provides that criminal cases in federal court can be tried by jury in the district or state where the crime has been committed. The criticism can be found in the absence of any guarantee that a jury can be drawn from the neighborhood where the crime has been committed, also known as “vicinage.” In the case of Salinger v. Loisel (1924), it was held that no accused can be tried in a district other than where the crime has been committed, even if there is an indictment. Further, the US Supreme Court in the case of Beavers v. Henkel (1904) held that the place where the offense has been committed determines the place of trial. 

In case an offense is committed against federal laws that does not involve commission of offense in any state or there is confusion as to the place where the crime has been committed, the Congress has been given the sole power to decide the place of trial. Such offenses are not local, and trials can be done at a place prescribed by Congress. This was also held by the US Supreme Court in the case of Jones v. United States (1890). However, the place of trial can also be decided by a statute after the commission of the offense. This was mentioned in the case of United States v. Johnson (1944). 

Non unanimous verdict in state courts

Recently, the US Supreme Court banned non-unanimous jury verdicts in serious cases. This decision of the Court was given in the case of Ramos v. Louisiana (2020). In this case, a man residing in Louisiana was convicted in 2016 of murdering a woman in New Orleans. The jury vote in this case was 10 to 2. Two of the jurors in this case felt that the prosecution failed to prove the guilt of the man beyond a reasonable doubt and that he must be acquitted. In history, courts in Louisiana have punished accused on such verdicts, even though in other states, a single vote to acquit amongst the jurors is enough to acquit a person. But the man in this case was sentenced to life imprisonment without any scope of parole. Louisiana later amended its Constitution to bar non-unanimous decisions, and now Oregon is the last and only state to permit such kinds of judgments. 

It was also observed by the Supreme Court in various cases that non-unanimous verdicts are prohibited by the Sixth Amendment as well. This was initially applicable to federal trials only. But after the 14th Amendment, the Sixth Amendment has widened its scope to include state trials as well, which also means that such verdicts will be barred in state trials as well. 

Attitude towards death penalty 

In some serious and heinous crimes, the death penalty is awarded to the offender. However, to award this penalty, a jury trial is required, which is different from other jury trials. In these trials, the jury does not only have to decide the guilt of the accused but also finalize whether to impose the death penalty. In cases where there is no possibility of awarding the death penalty, a single trial is conducted. However, in death penalty cases, a jury is chosen from the potential jurors for the trial. 

The death penalty cases are usually divided into two separate trials. In one trial, the jury examines the evidence in order to prove the guilt of the accused. If this is proved, the court proceeds with the second trial, in which the punishment is decided. During this trial, the jury has to decide the punishment from two options available to them. These are life imprisonment or the death penalty. This is done by weighing the aggravating factors against the mitigating factors presented by the prosecution. 

The right of the accused to be informed of the nature and cause of accusation

In order to serve the whole purpose of a trial, it is important that the accused be informed about the charges against him and why he has been accused of a particular offense so that he can consult assistance in this regard and present his side in quest of the truth. The Sixth Amendment guarantees the accused the right to be informed of the nature and cause of the accusation. This right is intended to ensure that the accused is aware of the charges against them and has the opportunity to adequately prepare a defense.

Under the Sixth Amendment, the accused must be given the opportunity to review the evidence against them and question any witnesses that may be called to testify. The accused must also be made aware of any changes to the charges and be given the opportunity to challenge any evidence that is presented against them.

In the case of Cruikshank v. United States (1875), the Supreme Court held that merely informing the accused of charges against him is not sufficient. The indictment or notice must provide other necessary details, like time and place of the crime, evidence against him, the punishment to be awarded if he pleads guilty, etc. Similarly, the Supreme Court in the case of Rosen v. United States (1896) held that the notice must describe the charges framed against the defendant or accused. This will help him/her to avoid double jeopardy in the future. 

Confrontation clause and right to cross-examine

The confrontation clause in the Sixth Amendment further prevents the admission of hearsay evidence. This is done because the accused did not have any opportunity to challenge its credibility or cross-examine the witness making such statements. The mandatory clause, on the other hand, in the amendment allows the defendant to call the witnesses to support his/her case. The Supreme Court of the US in the case of Bruton v. United States (1968) held that statements made by a defendant outside court can be admissible in court to prove his guilt, but the same is inadmissible against another defendant. 

The right to cross-examine a witness allows the accused to present his side of the story and prove his innocence. This also prevents the prosecution from asking questions that might convict the accused. The United States’ Supreme Court in the case of Crawford v. Washington (2004) widened the scope of the confrontation clause by stating that statements made outside court are inadmissible if the accused is not given an opportunity to cross-examine the person making such statements. It was observed that rights given in the Sixth Amendment were violated when the state admitted the statements of the accused’s wife that she made to the police. 

The right to assistance of counsel

The Sixth Amendment also guarantees the accused the right to assistance of counsel. This right is intended to ensure that the accused is given the opportunity to receive legal advice and representation during the criminal trial. If accused persons are deprived of this right, then they won’t be able to present their side, which will ultimately defeat the purpose of justice and the judicial department. One of the most important and established maxims in this regard, i.e., “audi alteram partem” which means “hear both the sides” also serves this purpose. The right to the assistance of counsel is a fundamental right in criminal proceedings and is one of the most important protections afforded to the accused. The assistance of counsel can be provided by a private attorney, a public defender, or a court-appointed lawyer.

The history of the right to the assistance of counsel can be traced back to the case of Powell v. Alabama (1932). In this case, Powell, along with nine other young defendants, was charged with the offense of rape. They did not have any friends or relatives in the area where the crime was committed. Due to the seriousness of the offense, they faced the public’s aggression. On the day of trial, two lawyers were appointed by the judge. They represented the defendants without any preparation, and they were convicted and sentenced to death in just one day of trial. The Supreme Court in this case ruled that assistance of counsel is an important and fundamental part of the accused’s right to a fair trial. The Court further directed the states to provide sufficient assistance to all the defendants who cannot afford to take assistance from a legal counsel. This assistance or help must be extended to illiterate and feeble minded people as well. 

Further, the Supreme Court extended its ruling in the Powell case to guarantee assistance of counsel to accused persons in all criminal cases at the federal level in the case of Johnson v. Zerbst (1938). In another historic case of Gideon v. Wainwright (1963), this assistance was further extended to felony cases at the state level. In this case, Gideon was arrested for the offense of burglary. Before his trial, he researched and came to know that he has the right to assistance of counsel under the Sixth Amendment and the 14th Amendment. As a result, he argued the same and filed a petition with the Supreme Court. 

The right to plead guilty

The Sixth Amendment also guarantees the accused the right to plead guilty. This right is intended to ensure that the accused is free to choose whether or not to enter a plea of guilty or not guilty.

Under the Sixth Amendment, the accused must be made aware of the charges against them and given the opportunity to enter a plea of guilty or not guilty. The plea must be entered freely and voluntarily, without coercion or duress. The concept of plea bargaining is also established and accepted in the US, wherein the prosecution and defense negotiate at a pretrial stage and the accused pleads guilty to the charges in exchange for a lesser punishment. However, the whole process is voluntary, and the accused decides whether he wants to do it or not. 

Case laws

United States v. Gonzalez-Lopez (2006)

Facts of the case

Gonzalez Lopez hired an attorney in this case to represent him, but the district court refused the attorney’s request to do so because he violated some rules in his previous case. As a result of this, Lopez was convicted. He appealed that his right under the Sixth Amendment to the paid chosen counsel had been violated and so the conviction must be overturned. 

Issues involved in this case

Whether the court should overturn the conviction of Lopez in this case?

Judgment of the Court

This case concerned the right to assistance of counsel, and the Supreme Court ruled that the accused had the right to be represented by an attorney of their choice. The Court held that the accused’s right to assistance of counsel had been violated when the trial court denied the defendant’s request to be represented by a particular attorney and so the conviction must be reversed. The Court also observed that the accused’s Sixth Amendment rights had been violated when the trial court failed to inform the defendant of all the charges against him and the reason for the accusation, along with other details of the case.  

Maryland v. Shatzer (2010)

Facts of the case

In this case, Mr. Shatzer was accused of sexually abusing a three-year-old child. Subsequently, he was interrogated for the same, during which he invoked his right to remain silent and the Fifth Amendment to the US Constitution. As a result of which the interrogation was terminated. The case was reopened in 2006 when his wife made specific allegations against him. This time he confessed his guilt, but before the trial he argued to suppress his confession, stating that he still had the right to remain silent. But the trial court of Maryland denied his motion and convicted him. During his interrogation, he remained in Miranda’s custody for more than 2 weeks, during which he alleged that his rights under the Sixth Amendment had been violated. 

Issues involved in the case

Whether there has been a violation of the Sixth Amendment?

Judgment of the Court

The Court held that the accused’s Sixth Amendment right to assistance of counsel had been violated when the defendant was denied access to counsel for 14 months while in pre-trial detention. It was also observed that a 14-day period is appropriate for a person to be re-acclimated. Since he remained in custody for more than two weeks, his rights to confrontation have been violated under the Sixth Amendment. 

Missouri v. Frye (2012) 

Facts of the case

In this case, Frye was charged with driving without a proper license. He was also convicted of the same offense thrice before the current case. Due to this, he was charged with a felony. His counsel was sent two plea bargains by the prosecution, which were never communicated to Frye. Before his hearing, he was again arrested for the same offense, pleaded guilty, and sentenced to three years of imprisonment. He further alleged that his counsel failed to inform him regarding the plea offers given by the prosecution. 

Issues involved in the case

Whether the right to effective assistance of counsel given under the Sixth Amendment of the US Constitution was violated in this case?

Judgment of the Court

The Roberts Court in this case observed that the right to effective assistance also applied to guilty pleas. It is the duty of the defense counsel to inform the accused of any offers made by the prosecution regarding a plea bargain. If he fails to do so, it renders the assistance ineffective. Thus, the accused’s rights in this case were violated. However, the Court in this case concluded that the state appellate court failed by not asking the accused to prove that there existed a reasonable opportunity where he would have accepted the plea that lapsed and also that the prosecution would have adhered to it. 

Conclusion

In any justice system, a fair trial can only happen if its principles are adhered to. One of the most improved principles is to hear both sides. This also means that where the victim is represented by a prosecutor, the accused must also be represented by a counsel. He must also be given certain rights to present his case and prove his innocence. Otherwise, the justice system would fall apart. Another important principle of a fair trial is having an impartial judge or jury. Only an impartial or neutral judge can give proper justice. All these rights have been granted to the citizens of the United States by the Sixth Amendment, which incorporated these rights into the Constitution. 

The Sixth Amendment of the United States Constitution is an important part of the Bill of Rights. It guarantees the accused the right to a speedy and public trial, the right to an impartial jury, the right to be informed of the nature and cause of the accusation, etc., which also forms a part of a fair trial. The Sixth Amendment has been interpreted in several landmark Supreme Court cases, such as United States v. Gonzalez-Lopez, Maryland v. Shatzer, and so on, which have helped in extending its scope to the extent that the accused persons are now aware of their rights and cannot be exploited. 

Frequently asked questions (FAQs)

How is the Fourteenth Amendment related to the Sixth Amendment?

The Fourteenth Amendment to the US Constitution established equal protection for all citizens and required due process to be followed. This further created the idea that all citizens must be treated equally under all laws, whether federal or state. As a result, the Sixth Amendment, which was initially applicable to federal laws only, is now applicable to state laws as well. 

What happens if the Sixth Amendment is violated ?

The remedy against the violation of the Sixth Amendment would be to dismiss the charges against the accused without any prejudice. This was held in the case of Strunk v. United States (1973).

What do you mean by right to effective assistance?

Whenever assistance is provided to the accused under the Sixth Amendment, the counsel must fulfill his duties effectively and without any prejudice or bias. He must represent the defendant properly. In the case of Strickland v. Washington (1984), the Supreme Court adopted a standard to determine whether the counsel was effective or not. According to the standard, if the defendant is able to prove that his counsel made serious mistakes and that if there had been another counsel, the verdict would have been different, then the court will reverse the conviction. 

References

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