Matter ofowski, 26 N.Y.2d 764 (1970)
The New York State Constitution guarantees the right to a jury trial in forfeiture proceedings because such proceedings were tried by jury before the adoption of the 1846 Constitution.
Summary
This case concerns whether a party is entitled to a jury trial in a forfeiture proceeding. The Court of Appeals held that the State Constitution guarantees such a right because forfeiture proceedings were historically tried by jury. The statute in question did not explicitly prohibit a jury trial, therefore the court was obligated to provide appropriate proceedings, including a jury trial as mandated by the Constitution. The failure to do so deprived the respondent of his constitutional right, warranting a modification of the Appellate Division’s order and a remand for a jury trial.
Facts
The facts of the underlying forfeiture proceeding are not detailed in this memorandum opinion. The focus is solely on the procedural question of whether a jury trial was required.
Procedural History
The Supreme Court denied the respondent a jury trial in a forfeiture proceeding. The Appellate Division’s order is not specified, but it was appealed to the New York Court of Appeals.
Issue(s)
Whether the respondent was deprived of his constitutional right to a jury trial in a forfeiture proceeding.
Holding
Yes, because section 2 of article I of the State Constitution guarantees the right to a jury trial in this forfeiture proceeding, as such proceedings were tried by jury before the adoption of the 1846 Constitution.
Court’s Reasoning
The court based its reasoning on the historical practice of trying forfeiture proceedings before a jury prior to the 1846 Constitution. It cited cases such as Colon v. Lisk and People ex rel. Lemon v. Elmore to support this historical precedent. The court also referenced secondary sources like Lincoln’s Constitutional History of New York. The court emphasized that the constitutional guarantee of a jury trial extends to cases where that right existed at the time of the constitution’s adoption.
The court distinguished Lawton v. Steele, which permitted summary destruction of property of small value to abate a nuisance, noting that the instant statute did not prohibit trial by jury, so it was incumbent on the court to provide the appropriate proceedings, including a jury trial mandated by the Constitution. The Court stated, “Hence it was incumbent on the court to provide the appropriate proceedings, including a jury trial mandated by the Constitution. The Supreme Court deprived respondent of his constitutional right by failing to afford respondent a jury trial.”
By failing to provide a jury trial, the Supreme Court deprived the respondent of a right guaranteed by the New York State Constitution. This decision reinforces the importance of historical practice in interpreting constitutional rights and clarifies that statutes must be interpreted in light of these constitutional guarantees.