Benton v. Maryland
Benton v. Maryland is a significant Supreme Court case decided in 1969 that addressed the constitutional principle of double jeopardy, which protects individuals from being tried twice for the same crime. The case emerged after the Supreme Court overturned a previous decision, Palko v. Connecticut, which had allowed for double jeopardy at the state level. In Benton, the Court ruled in a 7-2 decision that the Fifth Amendment's double jeopardy protections apply to state courts through the Fourteenth Amendment's incorporation doctrine. This landmark ruling emphasized that being tried again for a crime after an acquittal violates fundamental rights and is inconsistent with the principles of American justice. Justice Thurgood Marshall authored the opinion, highlighting the long-standing tradition against double jeopardy as essential to fair legal proceedings. The case marked a pivotal moment in the expansion of individual rights within the American legal system, affirming that protections against double jeopardy are a critical component of due process for all citizens.
Benton v. Maryland
Date: June 23, 1969
Citation: 395 U.S. 785
Issue: Double jeopardy
Significance: The Supreme Court ruled the Fifth Amendment protection against double jeopardy applied to the states through the due process clause of the Fourteenth Amendment.
In a 7-2 vote, the Supreme Court overturned Palko v. Connecticut (1937) and struck down Benton’s second conviction in Maryland courts as a violation of his Fifth Amendment rights. Justice Thurgood Marshall, in the opinion for the Court, stated that the double jeopardy provisions of the Fifth Amendment applied to the states through the incorporation doctrine of the Fourteenth Amendment, and therefore, a person who had been acquitted of a crime in a state court could not be tried again for the same crime.
In Palko, the Court had allowed double jeopardy in Connecticut, saying that the only rights that applied to the states under the due process clause of the Fourteenth Amendment were those closely related to the concept of “ordered liberty.” In reversing Palko, the Court recognized that although it had earlier not believed that a double jeopardy conviction was a universally “shocking” violation of justice, a prohibition against double jeopardy was, in fact, a long-standing practice that was fundamental to the American system of justice.