Singer v. United States

In Singer v. United States, 380 U.S. 24, 34-38, 85 S. Ct. 783, 13 L. Ed. 2d 630 (1965), defendant Singer argued "that a defendant in a federal criminal case has not only an unconditional constitutional right, guaranteed by Art. III, 2, and the Sixth Amendment, to a trial by jury, but also a correlative right to have his case decided by a judge alone if he considers such a trial to be to his advantage." 380 U.S. at 25-26. Thus, Singer claimed that Federal Rule of Criminal Procedure ("Federal Rule") 23, which required the United States to consent to any waiver of the jury-trial right, was unconstitutional. Id. at 26. The Court rejected Singer's claim, concluding that a defendant has no constitutional right to waive a jury trial and that Federal Rule 23(a) "sets forth a reasonable procedure governing attempted waivers of jury trials." Id. The Court further explained why the government is entitled to withhold consent: The Constitution recognizes an adversary system as the proper method of determining guilt, and the Government, as a litigant, has a legitimate interest in seeing that cases in which it believes a conviction is warranted are tried before the tribunal which the Constitution regards as most likely to produce a fair result. This recognition of the Government's interest as a litigant has an analogy in Rule 24(b) of the federal rules of criminal procedure, which permits the Government to challenge jurors peremptorily. Id. at 36. In Singer, the United State Supreme Court determined that neither Article III, Section 25 nor the Sixth Amendment6 jury-trial guarantee grant a correlative right to a defendant to have his guilt determined by a judge alone, and therefore rejected Singer's claim that Federal Rule of Criminal Procedure 23(a), the federal analogue to Rule 18.1(b), violated his constitutional rights by placing conditions on his ability to waive trial by jury. 380 U.S. at 37-38. In concluding that the Constitution is not violated by conditioning a defendant's waiver on the consent of the prosecuting attorney, the Court recognized that: The Government, as a litigant, has a legitimate interest in seeing that cases in which it believes a conviction is warranted are tried before the tribunal which the Constitution regards as most likely to produce a fair result. Id. at 36. In Singer v. United States, the United States Supreme Court analyzed the issue "of converse rights" in the context of the waiver of the right to a trial by jury. In Singer, the defendant argued that his right to waive a jury could not be limited by the requirement that the prosecutor and court also agree to the waiver. In rejecting this claim, the Court held the ability to waive a constitutional right does not ordinarily carry with it the right to insist upon the opposite of that right. For example, although a defendant can, under some circumstances, waive his constitutional right to a public trial, he has no absolute right to compel a private trial; although he can waive his right to be tried in the State and district where the crime was committed, he cannot in all cases compel transfer of the case to another district; and although he can waive his right to be confronted by the witnesses against him, it has never been seriously suggested that he can thereby compel the Government to try the case by stipulation. Moreover, it has long been accepted that the waiver of constitutionals rights can be subjected to reasonable procedural regulations . . . . The Constitution recognizes an adversary system as the proper method of determining guilt, and the Government, as a litigant, has a legitimate interest in seeing that cases in which it believes a conviction is warranted are tried before the tribunal which the Constitution regards as most likely to produce a fair result. Singer, 380 U.S. at 34-36.