United States v. Hollingsworth

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A federal magistrate judge conducted a bench trial, entered a verdict of guilty, and sentenced defendant-appellant David Hollingsworth to six months in federal prison for a petty offense committed on a federal enclave. Hollingsworth appealed to the federal district court, which affirmed the magistrate judge's judgment and sentence. Hollingsworth then appealed to the Fifth Circuit Court of Appeals, arguing he had a right to a jury trial. The Fifth Circuit held that Hollingsworth did not have a right to trial before an Art. III judge, and that his trial, conviction, and sentence before a federal magistrate judge was constitutional. Because the Court was bound “never to anticipate a question of constitutional law in advance of the necessity of deciding it,” the holding applied only to defendants tried for petty offenses committed on federal enclaves obtained by Congress pursuant to Art. I, sec. 8, Clause 17. View "United States v. Hollingsworth" on Justia Law