Duncan v. Louisiana, 391 U.S. 145 (1968), was a significant United States Supreme Court decision which incorporated the Sixth Amendment right to a jury trial and applied it to the states. Background In October 1966, Gary Duncan, a 19-year-old African-American, was driving down a Louisiana highway when he noticed his nephew Bert Grant and cousin Bernard St. Ann with a group of four white teenagers, including Herman Landry, on the side of the road. He became concerned because his cousins had reported occurrences of "racial incidents" at the recently desegregated school. He pulled over the car, stepped out, and asked his cousins to get in the car. Landry insulted Duncan, calling him a racial slur. According to historian Matthew Van Meter, Duncan told Landry to go home, "reaching out to the boy's arm in a gesture that was both conciliatory and final." The white youths testified that Duncan slapped Landry at this point, but Duncan and his relatives denied it. Duncan was arrested and ultimately charged with simple battery. As it was punishable by no more than two years, simple battery is a misdemeanor under Louisiana law and so he was not subject to trial by jury. Duncan was convicted and received a 60-day prison sentence and a fine of $150. He appealed on the grounds that the state had violated the Sixth and Fourteenth Amendments guaranteeing his right to a jury trial. The Court accepted the case, under its appellate jurisdiction from the Louisiana State Supreme Court. Issue Do the Sixth and Fourteenth Amendments guarantee the right to jury trial in state prosecutions where sentences as long as two years may be imposed? Majority opinion Justice White noted that the right to a jury trial for criminal offenses is a deeply enshrined value in the British and American legal traditions. Thus, right to a jury trial in criminal cases is within the 14th Amendment and so is applicable to the states. The question for the court was whether an offense subject to two years' imprisonment is a "serious offense." The majority noted that at the time of ratification, crimes punishable by more than six months imprisonment were typically subject to jury trial. Furthermore, both federal law and 49 states recognized that a crime carrying a sentence of over one year necessitated a jury trial. The Court found that the Louisiana law was out of sync with both the historical