In Duncan v. Louisiana, 391 U.S. 145 (1968), the Court held that an offense that carried a punishment of two years' imprisonment was serious and invoked the right to a trial by jury. The Court in Duncan did not establish a bright-line rule relating the right to a jury trial and the length of imprisonment, but emphasized that the legislature's maximum authorized penalty was the basis for determining whether an offense was serious or petty. Duncan, 391 U.S. at 161. The Court declared the provisions of the Sixth Amendment were applicable to state governments via the Fourteenth Amendment: Because we believe that trial by jury in criminal cases is fundamental to the American scheme of justice, we hold that the Fourteenth Amendment guarantees a right of jury trial in all criminal cases which--were they to be tried in federal court--would come within the Sixth Amendment's guarantee. Id. at 149. The Court further established that "in the American States, as in the federal judicial system, a general grant of jury trial for serious offenses is a fundamental right, essential for preventing miscarriages of justice and for assuring that fair trials are provided for all defendants." Id. at 157-58. However, the Court was careful to note: "we hold no constitutional doubts about the practices, common in both federal and state courts, of accepting waivers of jury trial and prosecuting petty crimes without extending a right to jury trial." Id. at 158. Duncan v. Louisiana established that a jury trial must be afforded to a defendant facing a serious offense.