United States v. Ollie Juanita Miller

468 F.2d 1041, 1972 U.S. App. LEXIS 7019
CourtCourt of Appeals for the Fourth Circuit
DecidedOctober 25, 1972
Docket72-1192
StatusPublished
Cited by11 cases

This text of 468 F.2d 1041 (United States v. Ollie Juanita Miller) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Ollie Juanita Miller, 468 F.2d 1041, 1972 U.S. App. LEXIS 7019 (4th Cir. 1972).

Opinion

BUTZNER, Circuit Judge:

Ollie Juanita Miller appeals from her conviction by a magistrate, affirmed by the district court, for unlawful concealment and possession of a firearm, in violation of Va.Code Ann. § 18.1-269, assimilated by 18 U.S.C. § 13. While we hold that the search of Mrs. Miller’s handbag and the seizure of the firearm from within it were lawful, we reverse for failure of the magistrate to properly apprise Mrs. Miller of her right to a jury trial in the district court.

I

Carrying a concealed weapon is a minor offense because the maximum punishment provided by the Virginia statute is confinement in jail for not more than 12 months and a fine of not more than $500. 1 Mrs. Miller, therefore, was entitled to elect to be tried by a jury. Cf. Callan v. Wilson, 127 U.S. 540, 8 S.Ct. 1301, 32 L.Ed. 223 (1888); see United States v. Merrick, 459 F.2d 644, 646 (4th Cir. 1972) (dictum). She complains that she was not properly advised by the magistrate of this right, and the record supports her. The magistrate explained her option to be tried in the district court, but not her right to a jury trial. 2

*1043 The Federal Magistrates Act requires the magistrate to “carefully explain” to a defendant charged with a minor offense that he has a right to a trial by a jury. So that there may be no misunderstanding about the importance of this explanation, the Act directs that the magistrate “shall not proceed to try the case unless the defendant, after such explanation, signs a written consent . . . . ” 3 This statute is amplified by the Federal Rules of Procedure for the Trial of Minor Offenses before United States Magistrates, which became effective January 27, 1971. Rule 2(b), which deals with minor offenses other than petty offenses, specifically directs the magistrate to “also explain to the defendant that he has a right to trial before a judge of the district court and a jury . ” Rule 2(c) provides that the consent must contain a waiver of “trial before a judge of the district court and a jury.” As the legislative history of the Act clearly demonstrates, literal compliance with the magistrate’s duty to explain the defendant’s rights is required to validate the waiver. 4

Third, even a' specially designated magistrate will be unable to exercise his jurisdiction unless both the prosecutor and the accused consent. The magistrate will be required to give every defendant brought before him a careful explanation of his right to elect *1044 trial before a judge of the district court and of his right, in appropriate cases, to demand trial by jury before that judge. S. 945 specifically forbids the magistrate to proceed to trial unless the defendant, having heard the magistrate’s explanation, executes a written election to be tried before the magistrate and a written waiver of whatever jury trial rights he has. 114 Cong.Rec. 27,341 (1968).

In McCarthy v. United States, 394 U.S. 459, 89 S.Ct. 1166, 22 L.Ed.2d 418 (1969), the Supreme Court held that the procedures for accepting a plea of guilty set forth in Rule 11 of the Federal Rules of Criminal Procedure were mandatory and not permissive. Consequently, the Court ruled, noncompliance constituted reversible error. We conclude that the rationale of McCarthy applies equally to the explanation of a defendant’s rights required by the Magistrates Act and the Rules. In McCarthy the Court reasoned that strict adherence to Rule 11 was mandatory because unless a guilty plea is voluntary and knowing, its acceptance deprives a defendant of due process of law. By analogy, we believe that strict adherence to § 3401(b) and Rules 2(b) and (c) is required because the magistrate’s trial of a minor offender who is ignorant of his right to be tried by a jury prevents him from asserting his constitutionally protected demand for a jury.

The government argues that the written consent to be tried by the magistrate, which Mrs. Miller executed in the-presence of her counsel, qualifies as a waiver of her right to a jury trial and cures the magistrate’s error. 5 The Act, however, requires both an explanation and a written consent. By its terms the consent is not to be signed until after the defendant has heard the magistrate’s explanation. Moreover, while the form which Mrs. Miller signed referred to her right to be tried before a district judge, it erronously described the crime as a petty offense and did not unequivocally advise her of her right to be tried by a jury. Execution of the form did not operate to waive a right that was never explained or understood. Johnson v. Zerbst, 304 U.S. 458, 58 S.Ct. 1019, 82 L.Ed. 1461 (1938). Contrary to the government’s assertion, Mrs. Miller’s written consent standing alone is inadequate to cure the omission of the explanation of the right to a jury trial, which is required by the express language of the statute and the rule.

The government also contends that Mrs. Miller may not press the point in this court because she failed to raise it in the district court. The government, however, has not shown that Mrs. Miller knew of the defect in the magistrate’s proceedings at the time she appeared in the district court. Moreover, the attorney who represented her before the magistrate was not the same person who represented her in the district court, and there is no showing that the latter was aware of the procedure followed by the magistrate when he arraigned Mrs. Miller. The omission in the magistrate’s explanation was not detected until a third lawyer undertook her appeal to this court. We need not decide whether the magistrate’s error constituted a jurisdictional flaw that could be raised in every case in which it might occur at any stage of the proceedings. It is sufficient to hold that since it substantially affected Mrs. Miller’s constitutional *1045 right to a trial by a jury, it may be noticed by us as plain error under Rule 52 of the Federal Rules of Criminal Procedure.

In sum, before a magistrate embarks upon the trial of a person charged with a minor offense, he must comply with § 3401 and Rule 2 by explaining to the defendant that he has a right to a trial before a judge of the district court and a jury.

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Bluebook (online)
468 F.2d 1041, 1972 U.S. App. LEXIS 7019, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-ollie-juanita-miller-ca4-1972.