United States v. Jackson

20 L. Ed. 2d 138 · Supreme Court of the United States · 1968

Facts

A federal grand jury in Connecticut returned an indictment charging three defendants with transporting a kidnaped person from Connecticut to New Jersey. The victim was held for ransom and was harmed when liberated. The indictment was brought under the Federal Kidnaping Act, which provides for the death penalty if the jury recommends it and the victim was not liberated unharmed. This provision effectively meant that defendants who chose a jury trial faced a risk of death that those who pleaded guilty or waived a jury trial did not.

Procedural history

A federal grand jury in Connecticut indicted three defendants under the Federal Kidnaping Act. The District Court dismissed count one of the indictment, holding the Act unconstitutional because its death penalty provision impaired the free exercise of the right to jury trial. The Government appealed directly to the Supreme Court.

Issue

Does the death penalty provision of the Federal Kidnaping Act unconstitutionally burden a defendant's Fifth Amendment right not to plead guilty and Sixth Amendment right to a jury trial? If so, is the entire statute unconstitutional, or is the death penalty provision severable?

Holding

Yes, the death penalty provision of the Federal Kidnaping Act unconstitutionally burdens a defendant's Fifth and Sixth Amendment rights. However, this provision is severable from the rest of the statute, which remains valid and enforceable. The District Court's dismissal of the indictment was reversed.

Rule

A statutory provision that needlessly chills the exercise of basic constitutional rights, such as the right not to plead guilty and the right to a jury trial, is unconstitutional. The Federal Kidnaping Act's death penalty provision unconstitutionally penalizes defendants who assert their right to a jury trial by making them face a risk of death that those who plead guilty or waive a jury trial do not. An unconstitutional part of a statute is severable if it is functionally independent and it is not evident that the legislature would not have enacted the remaining provisions independently. The death penalty clause is severable because its removal does not alter the statute's substantive reach or operation, and Congress would have enacted the law without it.

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Case brief last reviewed 2026-08-31. Prepared by CaseReader from the published opinion.